MEMORANDUM DECISION AND ORDER Plaintiff Molly Cohen brings this employment discrimination action against Defendants Integrated Project Delivery Partners Inc. (“IPD”) and David Silverstein, alleging violations of the Americans with Disabilities Act, 42 U.S.C. §§12101-12213 (“ADA”), New York State Human Rights Law, N.Y. Exec. Law §§290-301, (“NYSHRL”), and New York City Human Rights Law, N.Y.C. Admin. Code §§8-101-8-131 (“NYCHRL”). (First Am. Compl. (“FAC”), ECF No. 31.)1 Specifically, Plaintiff alleges that Silverstein, the Chief Executive Officer of IPD, terminated Plaintiff from the company based on her known relationship and association with individuals with disabilities — that is, her parents. Defendants move for summary judgment pursuant to Federal Rule of Civil Procedure 56, seeking dismissal of all of Plaintiff’s claims. (Notice of Mot., ECF No. 61.) Defendants’ motion for summary judgment is DENIED. I. FACTUAL BACKGROUND Silverstein hired Plaintiff on September 11, 2017 to work for IPD as an Assistant Project Manager. (Defs.’ Local Rule 56.1 Statement of Material Undisputed Facts (“Defs.’ Rule 56.1 Statement”), ECF No. 62, 10; Pl.’s Local Rule 56.1 Counterstatement (“Pl.’s Rule 56.1 Statement”), ECF No. 67, at 13.) Plaintiff was also involved with assisting Silverstein with a cosmetics line that he was developing. (Defs.’ Rule 56.1 Statement 19; Pl.’s Rule 56.1 Statement at 24.) According to Defendants, Plaintiff began exhibiting performance issues shortly after she was hired. (Defs.’ Rule 56.1 Statement 15.) In particular, she allegedly arrived to work late, habitually missed parts of a weekly meeting, and failed to maintain organized work space and files for projects to which she was assigned. (Id.
15-16.) Defendants assert that Silverstein “consistently” and “on a rolling basis” offered Plaintiff constructive criticism and feedback about such performance issues. (Id. 17.) Plaintiff, on the other hand, claims that she “received praise for her work throughout her tenure at IPD.” (Pl.’s Rule 56.1 Statement at 18.) On December 21, 2017, Silverstein met with Plaintiff to discuss her year-end evaluation and performance review. (Defs.’ Rule 56.1 Statement 23; Pl.’s Rule 56.1 Statement at 27.) Defendants claim that at this meeting, Silverstein provided both positive feedback and constructive criticism, (Defs.’ Rule 56.1 Statement 24), including that Plaintiff needed to improve her “punctuality, organization skills, and follow-up with clients/contractors,” (id. 25). Plaintiff contends that the only constructive criticism that Silverstein offered during her review was about her punctuality. (Pl.’s Rule 56.1 Statement at 28.) According to Plaintiff, she disclosed to Silverstein during their meeting that her parents “are both sick and require care.” (Id. at 45 (quoting Decl. of Alex J. Hartzband (“Decl.”), Ex. 2 (Pl.’s Dep. Tr.), ECF No. 67-2, at 120:11).) She asserts that she told him that her mother “has a condition, has MS, and it makes it difficult [for her mother] to be [her] father’s primary caretaker, so that falls on [her] brother and [her].” (Id. (quoting Decl., Ex. 2 (Pl.’s Dep. Tr.), at 120:12-15).) During the meeting, Silverstein and Plaintiff also discussed holiday plans for the upcoming week. (Defs.’ Rule 56.1 Statement 30; Pl.’s Rule 56.1 Statement at 34.) Defendants claim that Plaintiff asked whether IPD’s office would be open between December 26, 2017 and December 29, 2017, and that Silverstein confirmed that the office would be open, and that Plaintiff was expected to work on those days. (Defs.’ Rule 56.1 Statement
