Aghamehdi v. Osram Sylvania, Inc.

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW HAMPSHIRE
Hossein Aghamehdi
v. Civil No. 17-cv-700-JD
Opinion No. 2019 DNH 029
OSRAM Sylvania, Inc.
O R D E R
Hossein Aghamehdi brings suit against his former employer,
OSRAM Sylvania, Inc., alleging violation of the New Hampshire
Whistleblowers’ Protection Act and wrongful discharge. OSRAM
moves to compel Aghamehdi to provide responses to several
interrogatories and requests for production of documents.
Aghamehdi objects to the motion.
Standard of Review
“Parties may obtain discovery regarding any nonprivileged
matter that is relevant to any party’s claim or defense and
proportional to the needs of the case.” Fed. R. Civ. P.
26(b)(1). When a discovery dispute arises, a party may move to
compel answers to interrogatories and requests for production of
documents.1 Fed. R. Civ. P. 37(a)(3)(B). The moving party bears
1 Under the Local Rules of this District, a party who moves
to compel discovery responses “shall file only that portion of
the discovery document that is objected to or is the subject of
the motion.” LR 37.1(a). OSRAM, nevertheless, filed copies of
additional discovery requests and responses. Although OSRAM did
not comply with Local Rule 37.1(a), the mistake does not require
the motion to be refiled.
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the initial burden of showing that it seeks relevant
information, and if satisfied, the opposing party then bears the
burden of showing that the discovery request is improper.
Rutledge v. Elliot Health Sys., 2018 DNH 042, 2018 WL 1187406,
at *1 (D.N.H. Mar. 7, 2018).
Background
In his complaint, Aghamehdi states that he is a registered
professional engineer with a specialty in mechanical
engineering. He began working at OSRAM in July of 2000 and was
promoted several times thereafter. Beginning in September of
2015, Aghamehdi worked as a product manager in OSRAM’s specialty
lighting group.
As a product manager, Aghamehdi oversaw development and
specifications for the horticultural lighting market. He
reported to Christian Leclerc, general manager of the specialty
lighting group. In February of 2016, Leclerc offered Aghamehdi
the position of product manager for the horticultural lighting
system. He accepted the offer and moved from Erie,
Pennsylvania, to Exeter, New Hampshire.
In December of 2016, Aghamehdi worked with Steve Graves,
who was an executive account manager, to submit a proposal to a
company in Canada. The Canadian company did not accept the
proposal because of the cost. Aghamehdi and Graves then worked
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to reduce the costs from a third-party installer in an effort to
have the proposal accepted.
Their work on the cost issue involved confidential pricing
information that Graves forwarded to Leclerc and other OSRAM
employees. The confidential information was disclosed to
another installer that was an OSRAM subsidiary. When Aghamehdi
learned that the confidential information had been disclosed to
the subsidiary, he notified Graves that he might have violated
laws pertaining to unfair competition and a restraint of trade.
Aghamehdi also said that the sales team had violated antitrust
laws. The sales team manager agreed that the disclosure
potentially violated the law.
Aghamehdi then worked with Graves to assist a British
Columbia customer with an OSRAM lighting system. Aghamehdi
learned about certain operational adjustments for the lighting
system from his own research and from a Danish customer.
Aghamehdi gave Graves that information and promised to send a
document about the adjustments. Aghamehdi composed the document
from his research on websites and from what he had learned from
the Danish customer and gave it to Graves.
A week later, Leclerc called Aghamehdi about the document,
accusing him of plagiarism. Aghamehdi sent an email to clarify
the sources for his document. Leclerc terminated Aghamehdi’s
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employment on March 2, 2017, citing plagiarism that was a
serious violation of company policy.
Aghamehdi brings claims for violation of New Hampshire’s
Whistleblowers’ Protection Act (RSA Chapter 275-E) and wrongful
discharge. He contends that he is entitled to reinstatement;
economic losses including wages, benefits, and lost earning
capacity; compensatory damages for emotional distress,
humiliation, inconvenience, and loss of enjoyment of life;
enhanced compensatory damages; and reasonable attorneys’ fees.
Discussion
OSRAM seeks to compel discovery that it contends is
relevant to its affirmative defenses of mitigation of damages
and misconduct based on after-acquired evidence. OSRAM also
contends that Aghamehdi has not provided a sufficient privilege
log to support withholding documents on the basis of privilege.
Aghamehdi objects.
A. Discovery Related to Mitigation of Damages
Aghamehdi’s claims both arise under New Hampshire law. As
is noted above, he is seeking, among other things, economic
losses including wages, benefits, and lost earning capacity.
Under New Hampshire law, “[i]t is well established that a party
seeking damages occasioned by the fault of another must take all
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reasonable steps to lessen his or her resultant loss.” Grenier
v. Barclay Square Commercial Condo. Owners’ Ass’n, 150 N.H. 111,
119 (2003).
Aghamehdi sought and obtained employment after he was
terminated by OSRAM. OSRAM seeks information about Aghamehdi’s
current employment in Interrogatory No. 17 and Request for
Production No. 20. Interrogatory 17 asked and was answered, as
follows:
17. Identify all jobs that you have held from March
2, 2017 to the present, including the identity of the
employer, the position title, the job duties, the
dates the position was held, the weekly working hours
of the position, the weekly rate of pay, and all other
forms of compensation, including but not limited to
bonuses, commissions, and the type and amount of all
fringe benefits (e.g. health insurance, life
insurance, pension, and profit sharing, etc.) and the
reasons why any such employment came to an end.
ANSWER: The plaintiff objects to this interrogatory
to the extent it is overbroad, unduly burdensome, and
seeks information disproportional to the needs of the
case. Subject to and without waiver of these
objections the plaintiff states as follows:
I was unemployed and searching for work from the
date of my termination until April 9, 2018, when I
began a consulting position earning $112.00 per hour.
On average I worked about 2 days a week in this
position. Effective August 13, 2018, I became
employed with the company that had hired me as a
consultant as a Senior Manufacturing Engineer. In
this new position, I am earning $80,000 annual salary,
and my benefits include health insurance, a $50,000.00
life insurance policy, and profit sharing.
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That answer was supplemented in a letter from Aghamehdi’s
counsel on November 2, 2018. Counsel continued to object on the
grounds that the interrogatory was overbroad and that
information about Aghamehdi’s current employer and employment
“has the potential to jeopardize the employee’s current
employment.” Doc. 16-2, at *5. Counsel nevertheless provided
additional information: “As of August 13, 2018, Mr. Aghamehdi
became employed as a Senior Manufacturing Engineer. In this
position he earns $80,000 a year. Please see the attached pay
advice enclosed and BATES stamped P87.” Counsel further
represented: “The plaintiff stated he would produce personnel
documents relevant to damages calculation, which is consistent
with New Hampshire court orders speaking to current-employer
document disclosure.”
Request 20 asked and was answered as follows:
20. Produce all documents identified in your response
to Interrogatory 17 or relied upon in responding to
Interrogatory 17 regarding employment you have had
since March 2, 2017, including but not limited to
offer letters, employment contracts, and job position
descriptions. We have supplied a blank Authorization
for you to complete to respond to this request.
ANSWER: The plaintiff objects to this Request to the
extent it is overbroad, unduly burdensome, and seeks
information disproportional to the needs of the case.
Subject to and without waiver of these objections, the
plaintiff states he will forward personnel documents
relevant to his damages calculation upon receipt of
his personnel file from his current employer.
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The authorization form provided for Request 20 states, with a
notarized acknowledgement of execution at the end:
AUTHORIZATION TO OBTAIN EMPLOYMENT RECORDS
TO: _________________________________________
(Provide complete name and address of employer)
I, HOSSEIN AGHAMEHDI, hereby authorize you to
release to McLane Middleton, Professional Association,
c/o Jennifer L. Parent, 900 Elm Street, PO Box 326,
Manchester, NH 03105-0326, all information and records
regarding my employment with your company, including,
but not limited to, records reflecting my
compensation, benefits, attendance, and performance.
You may accept a photocopy of this authorization.
_____________________________
Hossein Aghamehdi
Aghamehdi has not provided the personnel documents that he
promised in response to Request 20. The magistrate judge held a
discovery status conference with the parties on November 7,
2018. OSRAM states in the motion to compel that during the
conference OSRAM agreed to accept a certified copy of
Aghamehdi’s personnel file in lieu of serving a subpoena on the
employer. Aghamehdi’s counsel sent a letter dated December 3,
2018, which continued to object to providing information,
including a certified personnel file, from his current employer.
Counsel did provide a copy of the current employer’s letter,
dated June 12, 2018, offering employment to Aghamehdi, with
identifying information redacted. Aghamehdi did not provide the
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personnel file and continues to assert generally that the
requests are overbroad, unduly burdensome, and are seeking
inadmissible character evidence.
OSRAM contends that Aghamehdi’s responses are incomplete
because he has not provided “all responsive documents to these
requests, including his current employer’s name.” Doc. 16, at
*5. Aghamehdi argues that OSRAM is seeking, improperly,
information about his work performance and character evidence.
Aghamehdi cannot dispute that his claim for damages puts
his subsequent employment earnings and benefits at issue in this
case, making that information relevant for discovery. See
O’Garra v. Northwell Health, 2018 WL 502656, at *3 (E.D.N.Y.
Jan. 22, 2018); Queen v. City of Bowling Green, 2017 WL 4355689,
at *6 (W.D. Ky. Sept. 29, 2017); Zeller v. S. Cent. Emergency
Med. Servs., Inc. 2014 WL 2094340, at *5 (M.D. Pa. May 20,
2014). In addition, a defendant employer need not rely on the
plaintiff’s own statements about his mitigation efforts.
O’Garra, 2018 WL 502656, at *3. On the other hand, however, a
request for information to support a failure to mitigate damages
defense must be narrowly tailored to seek specific documents
related to the defense. Id. at *4. For that reason, a request
for the plaintiff’s entire personnel file is overly broad.
Zeller, 2014 WL 2094340, at *6.
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In this case, OSRAM is entitled to discovery of information
and documents related to the issue of mitigation of damages.
Aghamehdi shall produce the specific information identified in
Interrogatory 17, other than identification of his current
employer. Aghamehdi shall also produce the documents
“identified in your response to Interrogatory 17 or relied upon
in responding to Interrogatory 17 regarding employment you have
had since March 2, 2017, including but not limited to offer
letters, employment contracts, and job position descriptions,”
as asked for in Request 20. Aghamehdi may redact identifying
information about his current employer, and that part of Request
20 for the authorization form is denied.
B. After-Acquired Evidence Defense
OSRAM argues that it is entitled to other information from
Aghamehdi because it is relevant to its after-acquired evidence
defense. To date, the New Hampshire Supreme Court has applied
the after-acquired evidence defense only in breach of contract
cases. McDill v. Environamics Corp., 144 N.H. 635, 640 (2000).
The court held that “‘after-acquired evidence of employee
misconduct is a defense to a breach of contract action for wages
and benefits lost as a result of discharge if the employer can
demonstrate that it would have fired that employee had it known
of the misconduct.’” ACAS Acquisitions (Precitech) Inc. v.
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Hobert, 155 N.H. 381, 399 (2007) (quoting McDill, 144 N.H. at
641). The court also explained that “we address only the
propriety of applying the after-acquired evidence doctrine in
cases that do not involve terminations that violate public
policy, such as discrimination or retaliatory discharge.”
McGill, 144 N.H. at 640.
Despite that express limitation, the New Hampshire Supreme
Court also noted that other jurisdictions have applied the
after-acquired evidence doctrine in tort cases but “only to
mitigate an employee’s damages.” Id. at 641. “The doctrine is
used to limit the employee’s damages to the time between the
wrongful termination and the time the employer discovers the
misconduct, provided the fact finder concludes that the
employee’s misconduct was sufficient to terminate the employee.”
Id. (citing McKennon v. Nashville Banner Pub. Co., 513 U.S. 352,
362-63 (1995)). The court concluded that “[w]e believe this
approach is appropriate in tort cases because it properly
balances the employee’s entitlement to a remedy as a result of
the employer’s tortious conduct with an employer’s interest in
lawfully managing its business affairs.” Id.
In response to OSRAM’s motion to compel, the court raised
the possibility of certifying a question to the New Hampshire
Supreme Court about the application of the defense under New
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Hampshire law. The parties agreed that certification was not
necessary and that that the defense would apply as the New
Hampshire Supreme Court stated in McDill. Because the New
Hampshire Supreme Court relied on McKennon in stating the
standard that would apply in tort cases, this court will also
rely on McKennon and cases that have applied that standard.
“Where an employer seeks to rely upon after-acquired
evidence of wrongdoing, it must first establish that the
wrongdoing was of such severity that the employee in fact would
have been terminated on those grounds alone if the employer had
known of it at the time of discharge.” McKennon, 513 U.S. at
362-63. When misconduct of that magnitude is proven, the
employee is not entitled to reinstatement or front pay. Id. at
362. In awarding back pay, which is calculated from termination
to discovery of the severe misconduct, “the court can consider
taking into further account extraordinary equitable
circumstances that affect the legitimate interest of either
party.” Id. at 362.
In support of the after-acquired evidence defense, OSRAM
propounded the following discovery to Aghamehdi:
Interrogatories
22. Identify all social media accounts (e.g. Twitter,
Facebook, Linked In) and email addresses that you have
used since September 1, 2015, including the usernames
for each social media account and the email addresses.
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ANSWER: The plaintiff objects to this
interrogatory on the grounds that it is overbroad,
unduly burdensome, disproportional to the needs of the
case, and seeks information that is not relevant to
any issue in the case.
24. Identify the person named “Wangli” and describe
her relationship with you.
ANSWER: The plaintiff objects to this
interrogatory to the extent it asks the plaintiff to
describe Wangli’s relationship with the plaintiff
because to such extent the interrogatory is overbroad,
unduly burdensome, disproportional to the needs of the
case, and seeks information that is not relevant to
any issue in the litigation. Subject to and without
waiver of these objections, the plaintiff states as
follows:
The last I knew, Wangli was a Sales Manager with
Zhejiang Dotlighting Co., Ltd., 768# Anchang Road,
Kequiao North Industrial Development Zone, Shaoxing
City, Zhejiang Province, China.
Requests for Production of Documents
7. For the period of January 1, 2013 to the present,
produce all electronic mail messages in your
“h_aghamehdi@msn.com” account (sent to, received by,
or copied on) relating to your work for OSRAM, your
employment at OSRAM, your separation from employment
at OSRAM, your alleged reports of violations of the
law by representatives of OSRAM, this lawsuit, and the
alleged damages you have suffered and seek to recover
in this lawsuit.
ANSWER: The plaintiff objects to this Request on
the grounds that it seeks documents protected by
attorney-client privilege.
8. For the period of January 1, 2013 to the present,
produce all electronic mail messages in your
“ermaaa738@msn.com” account (sent to, received by, or
copied on) relating to your work for OSRAM, your
employment at OSRAM, your separation from employment
at OSRAM, your alleged reports of violations of the
law by representatives of OSRAM, this lawsuit, and the
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alleged damages you have suffered and seek to recover
in this lawsuit.
ANSWER: The plaintiff objects to this Request on
the ground that it seeks documents protected by the
spousal privilege.
9. For the period of January 1, 2013 to the present,
produce all documents, electronic mail messages, or
other written communications between you and Alicia M.
Rainville-Aghamehdi regarding your work for OSRAM,
your employment at OSRAM, your separation from
employment at OSRAM, your alleged reports of
violations of the law by representatives of OSRAM,
this lawsuit, and the alleged damages you have
suffered and seek to recover in this lawsuit.
ANSWER: The plaintiff objects to this Request on
the ground that it seeks documents protected by the
spousal privilege.
10. For the period of January 1, 2013 to the present,
produce all documents, electronic mail messages, or
other written communications between you and the e-
mail account “65392076@qq.com” relating to your work
for OSRAM, your employment at OSRAM, your separation
from employment at OSRAM, your alleged reports of
violations of the law by representatives of OSRAM,
this lawsuit, and the alleged damages you have
suffered and seek to recover in this lawsuit.
ANSWER: See BATES stamped documents P69 – P70.
11. For the period of January 1, 2013 to the present,
produce all documents, electronic mail messages, or
other written communications between you and the e-
mail account “hn_wangli@hotmail.com” relating to your
work for OSRAM, your employment at OSRAM, your
separation from employment at OSRAM, your alleged
reports of violations of the law by representatives of
OSRAM, this lawsuit, and the alleged damages you have
suffered and seek to recover in this lawsuit.
ANSWER: The plaintiff does not have possession,
custody or control of any documents responsive to this
Request.
12. For the period of January 1, 2013 to the present,
produce all documents, electronic mail messages, or
other written communications between you and the e-
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mail account “wangli@cn-naite.com” relating to your
work for OSRAM, your employment at OSRAM, your
separation from employment at OSRAM, your alleged
reports of violations of the law by representatives of
OSRAM, this lawsuit, and the alleged damages you have
suffered and seek to recover in this lawsuit.
ANSWER: See BATES stamped P71 – P86.
28. Produce all documents that you took from OSRAM at
any time during your employment including, but not
limited to, documents relating to your employment and
documents relating to your retirement.
ANSWER: Objection on grounds that the Request is
vague, overbroad and disproportionate to the needs of
the case. Subject to and without waiving the
objection, the plaintiff did not “take” any documents
from OSRAM. To the extent he was [sic] documents
related to his employment with OSRAM in his
possession, these were provided him in the course of
his employment.
1. Standard
Aghamehdi argues in his objection to the motion to compel
that OSRAM has not made a sufficient preliminary showing that he
would have been discharged if he had engaged in the alleged
misconduct and, therefore, that OSRAM’s discovery requests are
irrelevant to the defense. In support, Aghamehdi relies
primarily on Miranda v. Deloitte, 962 F. Supp. 2d 379 (D.P.R.
2013). He also argues that OSRAM is engaging in an
impermissible fishing expedition to examine his employment
records, his emails, and his social media accounts to find
information to support other grounds for asserting misconduct.
OSRAM contends, in response, that Aghamehdi is imposing the
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standard for proving the defense which is not applicable to its
discovery requests.
In Miranda, the defendant raised an after-acquired evidence
defense based on its review of the plaintiff’s tax returns and
her deposition testimony and then asked to “announce” a tax
expert to review the returns. Miranda v. Deloitte, 962 F. Supp.
2d 379, 387 (D.P.R. 2013). The court noted that the defendant
did not have its own theory of the plaintiff’s misconduct but
instead hoped a tax expert would find misconduct to support the
defense. Id. The court denied the defendant’s motion to
“announce” a tax expert because “the defendants have not named
any alleged misconduct that occurred on the job, or any
employment policy indicating that an employee’s individual tax
return preparation and submission are relevant to or somehow
affect his or her job security.” Id.
Although a defendant cannot be required to prove its
defense in order to be entitled to discovery, the court must be
mindful about the nature of the after-acquired evidence defense
and the potential for abuse during discovery. An overly broad
scope of discovery for this defense would allow employers to
undertake fishing expeditions through an employee’s private
communications, financial records, personnel files, and other
matters looking for evidence of misconduct. See, e.g., Barger
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v. First Data Corp., 2018 WL 6591883, at *10 (N.D. Ala. Dec. 14,
2018) (“Federal courts are wary of allowing fishing-expedition
discovery by employers to find evidence of wrongdoing.”)
(internal quotation marks omitted); Alston v. Prairie Farms
Dairy, Inc., 2017 WL 4274858, at *2 (N.D. Miss. Sept. 26, 2017)
(“Defendant cannot use the after-acquired evidence defense to
conduct extensive discovery into the plaintiff’s prior
employment records on the basis of pure speculation.”) (internal
quotation marks omitted); Miranda, 922 F. Supp. 2d at 15-16.
Such an intrusion and investigation into an employee’s otherwise
private matters could become a deterrent to meritorious civil
rights, retaliation, and whistleblower claims. See Rivera v.
NIBCO, Inc., 364 F.3d 1057, 1070-72 (9th Cir. 2004).
For those reasons, the court has the responsibility imposed
by the Supreme Court to take appropriate measures to prevent
discovery abuses in the context of the after-acquired evidence
defense. McKennon, 513 U.S. at 363. Therefore, an employer is
not entitled to pursue discovery on an after-acquired evidence
defense “in the absence of some basis for believing that after-
acquired evidence of wrong-doing will be revealed.” Walker v. H
& M Henner & Mauritz, L.P., 2016 WL 4742334, at *1 (S.D.N.Y.
Sept. 12, 2016). An employer must articulate both alleged
misconduct by the employee and a basis in employment policy or
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agreements for terminating the employee because of that conduct.
Miranda, 926 F. Supp. 2d at 387.
2. Application
OSRAM asserts that Aghamehdi engaged in misconduct while
employed at OSRAM that would have resulted in his termination,
if it had been known. Specifically, OSRAM states in its motion
(1) that Aghamehdi shared confidential and proprietary
information with his wife, (2) that he sent that information
from his OSRAM email account to his personal email account or to
others who were using social media, and (3) that he used this
information for some undisclosed personal reason. OSRAM also
asserts that Aghamehdi had an inappropriate relationship with a
representative of an OSRAM vendor.
a. Policies
OSRAM represents that it has “employee policies and a
handbook related to unauthorized use or disclosure of such
company-owned confidential and proprietary information.” Doc.
16 at 11. OSRAM, however, did not provide copies of or quotes
from company policies or a handbook to show what was prohibited.
Nor does OSRAM provide a basis to believe that violation of
those policies or the handbook would lead to termination.
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Therefore, discovery about actions that may have violated an
unnamed policy or handbook is not relevant.
b. Agreement
OSRAM also represents that Aghamehdi signed “OSRAM SYLVANIA
Companies Proprietary Rights Agreement” and quotes a part that
pertains to protecting confidential and proprietary information.2
OSRAM asserts that it believes Aghamehdi took confidential or
proprietary information from OSRAM by using his OSRAM email
account to send the information to his personnel email, shared
that information with his wife and others by email and social
media, and used the information for his own purposes. Aghamehdi
argues that OSRAM has not shown enough to support discovery
based on the agreement.
Because OSRAM presumably has access to Aghamehdi’s OSRAM
email account, it should have more than a belief about what
those emails contain. See Walker, 2016 WL 4742334, at *1.
Further, OSRAM does not cite a provision that Aghamehdi would
have been terminated if he violated the agreement. These are
matters within OSRAM’s own knowledge and available information
and do not require discovery to develop. Therefore, OSRAM has
not provided enough to support discovery based on the agreement.
2 Aghamehdi does not deny that he signed the agreement.
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c. Relationship
OSRAM asserts that it suspects that Aghamehdi “engaged in
an inappropriate, undisclosed relationship with a representative
of an OSRAM vendor.” Doc. 16 at 12. OSRAM further asserts that
“[s]uch an inappropriate relationship would have constituted
grounds for disciplinary action against [Aghamehdi] during his
employment.” Doc. 16 at 12-13.
OSRAM did not provide any factual support for its suspicion
of a relationship. In addition, while OSRAM states that an
inappropriate relationship would have resulted in “disciplinary
action,” it did not cite or quote any company policy, procedure,
or employment agreement to support that assertion. Further,
“disciplinary action” does not necessarily mean termination,
which is the operative event to invoke the defense. Therefore,
OSRAM has not shown that discovery aimed at an “inappropriate
relationship” is relevant to the defense.
d. Disputed Discovery Requests
OSRAM seeks responses to Interrogatories 22 and 24 and to
Requests 7-12, and 20 based on the after-acquired evidence
defense. Because OSRAM has not provided sufficient support for
its asserted after-acquired evidence defense, those requests are
denied.
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In response to Request 28, Aghamehdi represented that he
did not take any of the documents described but that he does
have documents from OSRAM. Aghamehdi shall produce copies of
all OSRAM documents in his possession, regardless of how they
may have come into his possession.
C. Attorneys’ Fees and Costs
In closing, OSRAM asks the court to “[a]ward OSRAM costs,
including interest and attorneys’ fees incurred in connection
with this motion.” Doc. 16, at 14. OSRAM provides no further
discussion to support its request. Given OSRAM’s limited
success on its motion to compel, an award of attorneys’ fees and
costs is not appropriate. Fed. R. Civ. P. 37(a)(5)(A).
Conclusion
For the foregoing reasons, OSRAM’s motion to compel
(document no. 16) is granted in part and denied in part.
Aghamehdi shall provide to OSRAM:
(1) information requested in Interrogatory 17 that has not
already been provided, excluding the plaintiff’s current
employer’s name;
(2) the documents requested in Request 20 that correspond
to the information provided in response to Interrogatory 17 with
the current employer’s name redacted; and
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(3) the information requested in Request 28 as is provided
in this order.
The motion to compel is otherwise denied.
Aghamehdi shall provide the responses, as required in this
order, to OSRAM on or before March 8, 2019.
SO ORDERED.
______________________________
Joseph A. DiClerico, Jr.
United States District Judge
February 25, 2019
cc: Nicholas F. Casolaro, Esq.
Megan E. Douglass, Esq.
Benjamin T. King, Esq.
Jennifer L. Parent, Esq.
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