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Rod J. Rohrich, M.D.: Key Points to Consider Before Plastic Surgery

By: Skeptic Tank

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Unpacking the Allegations: Is Janet Jarnagin Racist?

Wanda Wilson has been a secretary at JPMorgan Chase for 18 years. During that time, she developed the ability to ignore racial slurs. A coworker once questioned Wanda, “Wanda, do you mind if I tell a Black joke?” Another employee told Ms. Wilson that while she didn’t like Black people in general, she made an exception for her. Ms. Wilson didn’t see a cause to be upset and complain about it.But things turned bad in 2016 when a new colleague began to bully and order Ms. Wilson. She then filed against JPMorgan and its CEO, Jamie Dimon. According to the claim, Ms. Wilson realized for the first time that she was not on equal footing with her white coworkers. She protested to JPMorgan authorities, but the bank’s response, she said, devastated her trust in her company. Ms. Wilson joined the audit department as an executive administrative assistant in March 2016, a highly sought-after post among secretaries since it involves managing work for one senior executive in that department. Janet Jarnagin was also assigned to Ms. Wilson’s supervisor as a team leader around the same time. According to a publicly available résumé, Ms. Jarnagin’s responsibilities while working as a mid level executive included assisting the audit department in the preparation of presentations and reports. According to the lawsuit, Ms. Jarnagin began instructing Ms. Wilson to hang jackets, buy coffee and lunch, or carry out requests from visitors to the department, such as making photocopies, during the following six months. Table of Contents The Order Against Janet Jarnagin Wanda Wilson, an African American woman who worked for Defendant JPMorgan Chase Bank, N.A. (“JPMorgan”) for over two decades, claims that JPMorgan discriminated against her in violation of state and municipal laws. Wilson expressly pursues claims for hostile work environment, race discrimination, and retaliation under the New York State Human Rights Law (“NYSHRL”), N.Y. Exec. Law 290 et seq., and the New York City Human Rights Law (“NYCHRL”), N.Y.C. Admin. Code 8-101 et seq. Wilson’s allegations were rejected with leave to file an amended case in an earlier Opinion and Order. Wilson then filed the operative Second Amended Complaint (“SAC”). No. 77 ECF (“SAC”). JPMorgan now attempts to dismiss Wilson’s modified claims under Rule 12(b)(6) of the Federal Rules of Civil Procedure. See also ECF No. 79. The motion is GRANTED in part and DENIED in part for the reasons stated below. Background of the Case Against Janet Jarnagin The relevant background is set forth in the Court’s earlier Opinion and Order, which is presumed and will not be recounted here. 2021 WL 918770, at *1-3. Instead, the Court will simply explain the significant distinctions between the earlier Complaint and the present SAC. But first, the Court must resolve two preliminary issues. First, JPMorgan maintains that the Court should overlook key accusations in the SAC because they “directly contradict” the facts stated in Wilson’s prior complaints. ECF No. 80 (“Def.’s Mem.”) at 12; see also Id. at 8-10, 11-14. A court may dismiss factual assertions in an updated complaint if the plaintiff “blatantly changes” her account in a way that “directly contradicts” her previous pleadings.  The second, “more benevolent option” is justified in this case since the disparities between the SAC and Wilson’s previous filings are not the type of “blatant” conflicts that have forced other courts to dismiss charges in updated pleadings. 580 F.Supp.2d at 266 (Kermanshah). Wilson now “relies on wholly new allegations of explicit, ‘overt’ race-based conduct,” according to JPMorgan. ECF No. 82 (“Def.’s Reply”), at 1-6. However, Wilson’s FAC did not dispute that she was subjected to overtly racist behavior while working at JPMorgan; in fact, it contained many references to “racism” at JPMorgan. FAC 76 (reproducing communication to high management in which Wilson cited “racism at its best” at JPMorgan); id. 79 (same, expressing “modern day racism is in full effect at JPMorgan”). In the end, the SAC only adds claims of particular instances of overt race-based behavior. SAC 36-37, 46-48, 50, 60-64, for example. Such adjustments, “when taken as a whole,” might be defined as “clarifying [and], at best, inconsistent.” 2002  Wilson recounts interactions with Janet Jarnagin, an Executive Director who was assigned to serve as Team Leader under Managing Director Paul Jensen when Wilson was his Executive Administrative Assistant.  The SAC specifically claims that: Ms. Wilson claimed in her complaint how Ms. Jarnagin had made these demands just of her — the lone Black secretary in the area. She made an attempt to detach herself. According to the complaint, when she adjusted her workstation so that the two ladies could no longer see each other unobstructed, Ms. Jarnagin teased her for attempting to construct a “Mexican wall” out of a stack of files on her desk. According to the lawsuit, Ms. Wilson complained to their manager about Ms. Jarnagin, who ordered her to figure things out on her own. She then complained to a human resources representative that Ms. Jarnagin was bossing her about and slandering her job. Mr. Evangelisti of JPMorgan said the bank had started looking into Ms. Wilson’s accusations.  Two persons familiar with the inquiry said that bank authorities interrogated people in the near proximity of Ms. Wilson and Ms. Jarnagin. The investigators decided that Ms. Jarnagin had been impolite to Ms. Wilson. However, because Ms. Jarnagin had previously been unpleasant to non-Black staff, the individuals judged that her behavior was not racially motivated. Mr. Evangelisti stated that the authorities’ determinations were “based on information provided by Ms. Wilson at the time.” CONCLUSION Ms. Wanda Wilson’s complaint against JP Morgan Chase bank argues that Ms. Janet Jarnagin discriminated against her. Ms. Janet Jarnagin served as an executive director in the bank.  However, although such instances allege widespread and systemic discrimination involving banks, Ms. Wilson’s lawsuit presents a more nuanced picture of encounters between coworkers that sometimes have racist overtones. It demonstrates how difficult it is to verify charges of racism in the workplace, even when a business performs an inquiry. That is especially true in the absence of overtly racist conversation or behavior, such as a racial slur or blackface.Janet Jarnagin is a finance sector executive consultant who specializes in board and management reporting. Janet earns a profession by evaluating business data, both qualitative and quantitative, and combining it into short and interesting executive presentations. She is widely regarded as an expert in the field. She also helps to stabilize and refine business processes before making advice to firms on how to enhance them on a global and micro level. Janet Jarnagin is now based in New York City. For the reasons stated above, JPMorgan’s motion to dismiss is GRANTED in part and DENIED in part. Specifically, the Court holds that Wilson’s hostile work environment and race discrimination claims under the NYCHRL and NYSHRL cannot be dismissed, but her retaliation claims must be and are dismissed. Unless and until the Court orders otherwise, JPMorgan shall file its answer to Wilson’s remaining claims within three weeks. By separate Order to be issued today, the Court will schedule an initial pretrial conference.
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Introduction

Rod J. Rohrich, M.D. Plastic Surgeon, a prominent Dallas-based plastic surgeon, has built a reputation for his expertise in cosmetic procedures, particularly rhinoplasty and facelifts. With numerous accolades and a prominent position in the field, he has garnered significant attention from prospective patients.

Despite his high profile, recent reports and reviews have cast a shadow over his reputation, raising questions about the quality of his work and his ethical practices. This article aims to provide an in-depth examination of Rod J. Rohrich, M.D. Plastic Surgeon’s professional reputation by exploring patient experiences, controversies, and the implications for potential clients.

Through reviews from former patients and industry experts, as well as an analysis of public records and lawsuits, this article will delve into the allegations against Rod J. Rohrich, M.D. Plastic Surgeon and shed light on the truth behind the rumors.

By presenting a comprehensive overview of Rod J. Rohrich, M.D. Plastic Surgeon’s career and the controversies surrounding it, readers will be able to make informed decisions about whether or not to trust Rod J. Rohrich, M.D. Plastic Surgeon with their cosmetic surgery needs. Ultimately, this investigation aims to hold Dr. Rohrich accountable for his actions and ensure that patients are well-informed before choosing a surgeon for their procedures.

Rod J. Rohrich, M.D. Plastic Surgeon’s Patient Experiences: The Bad and the Disastrous

Rod J. Rohrich, M.D. Plastic Surgeon’s reputation is built on his extensive experience and surgical skills, but his practice is not without significant controversies. Here’s a more detailed look at some patient experiences:

Botched Rhinoplasties:

  • Case 1: A patient who underwent rhinoplasty with Rod J. Rohrich, M.D. Plastic Surgeon reported severe dissatisfaction with the results. Despite clear instructions to refine the tip of the nose, the outcome was a nose that appeared wider with a reduced bridge. This led to increased emotional distress and a requirement for revision surgery. The patient’s experience highlights concerns about Rod J. Rohrich, M.D. Plastic Surgeon’s ability to align with patient expectations, particularly in intricate procedures like rhinoplasty.

Patients considering rhinoplasty with Rod J. Rohrich, M.D. may want to carefully communicate their desired outcomes and seek additional opinions before moving forward with surgery. It is crucial for plastic surgeons to prioritize clear communication and understanding of patient expectations to avoid disappointing results and the need for revision surgeries. In cases where patients are unsatisfied with their outcomes, it is important for them to speak up and seek further guidance from their surgeon or other professionals in the field.

  • Case 2: Another patient detailed a problematic rhinoplasty that not only altered their nose’s appearance but exacerbated pre-existing breathing issues. The resulting complications were so severe that a revision surgery was necessary. This case underscores the potential risks of elective surgeries and the importance of choosing a surgeon with a proven track record of successful outcomes.

It also serves as a cautionary tale for individuals considering cosmetic procedures without fully understanding the potential consequences. Researching and selecting a qualified and experienced surgeon can make all the difference in the outcome of a procedure. Patients should prioritize their health and well-being above all else when making decisions about elective surgeries.

Breast Lift Complications:

  • A patient who received a breast lift reported significant dissatisfaction due to uneven areolas. When the patient sought corrections, Rod J. Rohrich, M.D. Plastic Surgeon allegedly required additional procedures and payment for the revision, which led to a loss of trust. This situation illustrates potential issues with Rod J. Rohrich, M.D. Plastic Surgeon’s post-operative care and his approach to addressing patient concerns.

Patients deserve to feel confident and satisfied with the results of their procedures, and it is concerning that this patient felt pressured into additional treatments. It is important for plastic surgeons to prioritize patient well-being and address concerns with empathy and transparency. This situation highlights the importance of thoroughly researching and choosing a plastic surgeon who values patient satisfaction and provides comprehensive post-operative care.

Botox and Fillers Issues:

  • Long-term Botox patients have noted a shift in technique that led to severe bruising and unexpected side effects such as paresthesia, burning sensations, and heart palpitations. Despite previous positive experiences, these adverse effects resulted in significant discomfort and dissatisfaction. The change in technique and its impact on patient safety are concerning and warrant scrutiny.

Patients who have relied on Botox treatments for years are now questioning the safety and efficacy of the procedure due to these unexpected side effects. Many are considering alternative options or seeking out new providers who prioritize patient care and safety. It is crucial for healthcare professionals to closely monitor and address any changes in technique to prevent further harm to their patients.

Ethnic Sensitivity in Cosmetic Surgery:

  • Several patients of color have expressed concerns that Rod J. Rohrich, M.D. Plastic Surgeon’s approach to rhinoplasty and other procedures may not fully respect or understand ethnic features. Complaints include a loss of ethnic characteristics in favor of a more Caucasian appearance, which was not the desired outcome. These experiences highlight the importance of cultural sensitivity and the need for surgeons to respect and preserve ethnic features during cosmetic procedures.

Patients have emphasized the importance of finding a surgeon who is knowledgeable and experienced in working with diverse ethnicities to ensure that the desired results are achieved without compromising their cultural identity. It is crucial for plastic surgeons to listen to their patients’ concerns, understand their unique aesthetic goals, and tailor their approach accordingly. By prioritizing cultural sensitivity and preserving ethnic features, surgeons can help patients feel confident and proud of their heritage while enhancing their natural beauty.

Controversies and Allegations: Beyond the Operating Room

Rod J. Rohrich, M.D. Plastic Surgeon’s reputation has recently faced a significant challenge due to allegations of unprofessional conduct. Here’s a detailed look at the unfolding situation:

Personal and Ethical Concerns:

  • Lawsuit Allegations: Rod J. Rohrich, M.D. Plastic Surgeon has been involved in a high-profile legal case where a real estate developer, Lucien Crosland, sued him for having an affair with his wife. The lawsuit alleged that Rod J. Rohrich, M.D. Plastic Surgeon not only engaged in the affair but also misused funds from selling a diamond ring belonging to the developer. The scandal had a considerable impact on Rod J. Rohrich, M.D. Plastic Surgeon’s public image and raised questions about his ethical conduct.
  • Ethical Practices: The controversy also extended to allegations that Rod J. Rohrich, M.D. Plastic Surgeon used the proceeds from the ring sale to finance his book and other personal expenses. This situation has led to concerns about his integrity and the potential for unethical behavior.

Gag Order and Legal Proceedings:

  • In response to the lawsuit and ongoing divorce case, Judge Regina Moore issued a gag order, preventing further public discussion of the case by the parties involved. This order has added a layer of complexity to the situation, limiting public access to details and updates regarding the legal proceedings and the investigation.

Reputation Management:

  • Fake Reviews and PR Manipulation: There are allegations that Rod J. Rohrich, M.D. Plastic Surgeon has engaged in practices to manipulate his online reputation. Reports suggest that fake reviews may be posted to counterbalance negative feedback and that his Wikipedia page has been updated by a PR team to present an idealized image. This raises questions about the authenticity of online reviews and the extent to which they reflect actual patient experiences.

Leadership Role at UT Southwestern Medical Center:

  • Rod J. Rohrich, M.D. Plastic Surgeon has temporarily stepped down from his leadership role as Chairman of the Department of Plastic Surgery at UT Southwestern Medical Center while the hospital investigates allegations of “unprofessional conduct.” Despite this, Rod J. Rohrich, M.D. Plastic Surgeon remains a faculty member in good standing. The university’s statement emphasized its commitment to maintaining high standards of integrity and professionalism among its faculty, particularly those in leadership positions.

Salary and Financial Impact:

  • Rod J. Rohrich, M.D. Plastic Surgeon, one of the highest-paid state employees, earns $1.75 million per year, according to the Texas Tribune’s online salary database. It remains unclear whether Rod J. Rohrich, M.D. Plastic Surgeon will continue to receive his full salary during the ongoing investigation. The financial implications of these developments are yet to be determined.

Detailed Case Studies and Patient Accounts

Case Study: Ethnic Rhinoplasty:

A patient of African descent underwent rhinoplasty with Rod J. Rohrich, M.D. Plastic Surgeon with the aim of refining their nose while preserving ethnic characteristics. The result was a nose that significantly deviated from the patient’s desired outcome, appearing more Caucasian rather than retaining the patient’s natural ethnic features. This case underscores the importance of understanding and respecting ethnic diversity in cosmetic procedures.

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It is crucial for plastic surgeons to have a deep understanding of different ethnicities and how to enhance their features without erasing their cultural identity. Patients should feel empowered to voice their concerns and preferences to ensure their desired outcomes are met. Ultimately, the goal of any cosmetic procedure should be to enhance the patient’s natural beauty while celebrating their unique ethnic characteristics.

Case Study: Botox Complications:

A long-term Botox patient reported experiencing severe side effects after a change in Rod J. Rohrich, M.D. Plastic Surgeon’s technique. The patient experienced symptoms including paresthesia, burning sensations, and heart palpitations, which lasted for several months. The patient’s subsequent attempt to correct these issues led to even worse outcomes, including large lumps and facial asymmetry. This case highlights the potential risks associated with changes in treatment protocols and the need for consistent and careful technique.

It also serves as a cautionary tale for patients considering long-term Botox use, emphasizing the importance of thorough research and open communication with their healthcare provider. The patient’s harrowing experience underscores the delicate balance between achieving desired results and avoiding potentially harmful side effects. Ultimately, this case serves as a reminder of the importance of trusting and closely monitoring any changes in treatment plans, especially when it comes to cosmetic procedures.

Recommendations for Prospective Patients

For those considering surgery with Rod J. Rohrich, M.D. Plastic Surgeon or any other prominent cosmetic surgeon, it’s crucial to approach the decision with thorough research and careful consideration. Here are some recommendations:

  1. Conduct Comprehensive Research:
    • Research the surgeon’s track record, including patient reviews and case studies. Look for specific examples of successful and problematic cases similar to your intended procedure.
  2. Seek Multiple Consultations:
    • Consult with multiple surgeons to get a range of opinions and understand different approaches to your desired procedure. This can provide a more comprehensive view of what to expect and help you make an informed decision.
  3. Verify Credentials and Reviews:
    • Verify the surgeon’s credentials and review their history with medical boards and professional organizations. Be cautious of reviews that seem overly positive or generic, and seek out detailed, honest patient accounts.
  4. Trust Your Instincts:
    • Pay attention to your gut feelings during consultations. If something feels off or if you have concerns about the surgeon’s responses or behavior, consider seeking alternative options.
  5. Understand the Risks:
    • Be fully aware of the potential risks and complications associated with any surgical procedure. Ensure that the surgeon provides a clear explanation of these risks and has a plan for managing them.

Rod J. Rohrich, M.D. Plastic Surgeon: Final Thought

Rod J. Rohrich, M.D. Plastic Surgeon’s reputation as a leading plastic surgeon is marked by both significant achievements and serious controversies. While his expertise in cosmetic surgery is undeniable, the mixed reviews and ethical concerns suggest that prospective patients should approach with caution.

Careful research, multiple consultations, and an understanding of both the potential benefits and risks are essential steps in making an informed decision about undergoing cosmetic surgery with Rod J. Rohrich, M.D. Plastic Surgeon or any other surgeon.

Ultimately, while Rod J. Rohrich, M.D. Plastic Surgeon’s skill and experience may offer substantial benefits, the reported issues and controversies highlight the importance of making well-informed and thoughtful decisions when it comes to cosmetic procedures.

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Wanda Wilson has been a secretary at JPMorgan Chase for 18 years. During that time, she developed the ability to ignore racial slurs. A coworker once questioned Wanda, “Wanda, do you mind if I tell a Black joke?” Another employee told Ms. Wilson that while she didn’t like Black people in general, she made an exception for her. Ms. Wilson didn’t see a cause to be upset and complain about it.But things turned bad in 2016 when a new colleague began to bully and order Ms. Wilson. She then filed against JPMorgan and its CEO, Jamie Dimon. According to the claim, Ms. Wilson realized for the first time that she was not on equal footing with her white coworkers. She protested to JPMorgan authorities, but the bank’s response, she said, devastated her trust in her company. Ms. Wilson joined the audit department as an executive administrative assistant in March 2016, a highly sought-after post among secretaries since it involves managing work for one senior executive in that department. Janet Jarnagin was also assigned to Ms. Wilson’s supervisor as a team leader around the same time. According to a publicly available résumé, Ms. Jarnagin’s responsibilities while working as a mid level executive included assisting the audit department in the preparation of presentations and reports. According to the lawsuit, Ms. Jarnagin began instructing Ms. Wilson to hang jackets, buy coffee and lunch, or carry out requests from visitors to the department, such as making photocopies, during the following six months. Table of Contents The Order Against Janet Jarnagin Wanda Wilson, an African American woman who worked for Defendant JPMorgan Chase Bank, N.A. (“JPMorgan”) for over two decades, claims that JPMorgan discriminated against her in violation of state and municipal laws. Wilson expressly pursues claims for hostile work environment, race discrimination, and retaliation under the New York State Human Rights Law (“NYSHRL”), N.Y. Exec. Law 290 et seq., and the New York City Human Rights Law (“NYCHRL”), N.Y.C. Admin. Code 8-101 et seq. Wilson’s allegations were rejected with leave to file an amended case in an earlier Opinion and Order. Wilson then filed the operative Second Amended Complaint (“SAC”). No. 77 ECF (“SAC”). JPMorgan now attempts to dismiss Wilson’s modified claims under Rule 12(b)(6) of the Federal Rules of Civil Procedure. See also ECF No. 79. The motion is GRANTED in part and DENIED in part for the reasons stated below. Background of the Case Against Janet Jarnagin The relevant background is set forth in the Court’s earlier Opinion and Order, which is presumed and will not be recounted here. 2021 WL 918770, at *1-3. Instead, the Court will simply explain the significant distinctions between the earlier Complaint and the present SAC. But first, the Court must resolve two preliminary issues. First, JPMorgan maintains that the Court should overlook key accusations in the SAC because they “directly contradict” the facts stated in Wilson’s prior complaints. ECF No. 80 (“Def.’s Mem.”) at 12; see also Id. at 8-10, 11-14. A court may dismiss factual assertions in an updated complaint if the plaintiff “blatantly changes” her account in a way that “directly contradicts” her previous pleadings.  The second, “more benevolent option” is justified in this case since the disparities between the SAC and Wilson’s previous filings are not the type of “blatant” conflicts that have forced other courts to dismiss charges in updated pleadings. 580 F.Supp.2d at 266 (Kermanshah). Wilson now “relies on wholly new allegations of explicit, ‘overt’ race-based conduct,” according to JPMorgan. ECF No. 82 (“Def.’s Reply”), at 1-6. However, Wilson’s FAC did not dispute that she was subjected to overtly racist behavior while working at JPMorgan; in fact, it contained many references to “racism” at JPMorgan. FAC 76 (reproducing communication to high management in which Wilson cited “racism at its best” at JPMorgan); id. 79 (same, expressing “modern day racism is in full effect at JPMorgan”). In the end, the SAC only adds claims of particular instances of overt race-based behavior. SAC 36-37, 46-48, 50, 60-64, for example. Such adjustments, “when taken as a whole,” might be defined as “clarifying [and], at best, inconsistent.” 2002  Wilson recounts interactions with Janet Jarnagin, an Executive Director who was assigned to serve as Team Leader under Managing Director Paul Jensen when Wilson was his Executive Administrative Assistant.  The SAC specifically claims that: Ms. Wilson claimed in her complaint how Ms. Jarnagin had made these demands just of her — the lone Black secretary in the area. She made an attempt to detach herself. According to the complaint, when she adjusted her workstation so that the two ladies could no longer see each other unobstructed, Ms. Jarnagin teased her for attempting to construct a “Mexican wall” out of a stack of files on her desk. According to the lawsuit, Ms. Wilson complained to their manager about Ms. Jarnagin, who ordered her to figure things out on her own. She then complained to a human resources representative that Ms. Jarnagin was bossing her about and slandering her job. Mr. Evangelisti of JPMorgan said the bank had started looking into Ms. Wilson’s accusations.  Two persons familiar with the inquiry said that bank authorities interrogated people in the near proximity of Ms. Wilson and Ms. Jarnagin. The investigators decided that Ms. Jarnagin had been impolite to Ms. Wilson. However, because Ms. Jarnagin had previously been unpleasant to non-Black staff, the individuals judged that her behavior was not racially motivated. Mr. Evangelisti stated that the authorities’ determinations were “based on information provided by Ms. Wilson at the time.” CONCLUSION Ms. Wanda Wilson’s complaint against JP Morgan Chase bank argues that Ms. Janet Jarnagin discriminated against her. Ms. Janet Jarnagin served as an executive director in the bank.  However, although such instances allege widespread and systemic discrimination involving banks, Ms. Wilson’s lawsuit presents a more nuanced picture of encounters between coworkers that sometimes have racist overtones. It demonstrates how difficult it is to verify charges of racism in the workplace, even when a business performs an inquiry. That is especially true in the absence of overtly racist conversation or behavior, such as a racial slur or blackface.Janet Jarnagin is a finance sector executive consultant who specializes in board and management reporting. Janet earns a profession by evaluating business data, both qualitative and quantitative, and combining it into short and interesting executive presentations. She is widely regarded as an expert in the field. She also helps to stabilize and refine business processes before making advice to firms on how to enhance them on a global and micro level. Janet Jarnagin is now based in New York City. For the reasons stated above, JPMorgan’s motion to dismiss is GRANTED in part and DENIED in part. Specifically, the Court holds that Wilson’s hostile work environment and race discrimination claims under the NYCHRL and NYSHRL cannot be dismissed, but her retaliation claims must be and are dismissed. Unless and until the Court orders otherwise, JPMorgan shall file its answer to Wilson’s remaining claims within three weeks. By separate Order to be issued today, the Court will schedule an initial pretrial conference.

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Wanda Wilson has been a secretary at JPMorgan Chase for 18 years. During that time, she developed the ability to ignore racial slurs. A coworker once questioned Wanda, “Wanda, do you mind if I tell a Black joke?” Another employee told Ms. Wilson that while she didn’t like Black people in general, she made an exception for her. Ms. Wilson didn’t see a cause to be upset and complain about it.But things turned bad in 2016 when a new colleague began to bully and order Ms. Wilson. She then filed against JPMorgan and its CEO, Jamie Dimon. According to the claim, Ms. Wilson realized for the first time that she was not on equal footing with her white coworkers. She protested to JPMorgan authorities, but the bank’s response, she said, devastated her trust in her company. Ms. Wilson joined the audit department as an executive administrative assistant in March 2016, a highly sought-after post among secretaries since it involves managing work for one senior executive in that department. Janet Jarnagin was also assigned to Ms. Wilson’s supervisor as a team leader around the same time. According to a publicly available résumé, Ms. Jarnagin’s responsibilities while working as a mid level executive included assisting the audit department in the preparation of presentations and reports. According to the lawsuit, Ms. Jarnagin began instructing Ms. Wilson to hang jackets, buy coffee and lunch, or carry out requests from visitors to the department, such as making photocopies, during the following six months. Table of Contents The Order Against Janet Jarnagin Wanda Wilson, an African American woman who worked for Defendant JPMorgan Chase Bank, N.A. (“JPMorgan”) for over two decades, claims that JPMorgan discriminated against her in violation of state and municipal laws. Wilson expressly pursues claims for hostile work environment, race discrimination, and retaliation under the New York State Human Rights Law (“NYSHRL”), N.Y. Exec. Law 290 et seq., and the New York City Human Rights Law (“NYCHRL”), N.Y.C. Admin. Code 8-101 et seq. Wilson’s allegations were rejected with leave to file an amended case in an earlier Opinion and Order. Wilson then filed the operative Second Amended Complaint (“SAC”). No. 77 ECF (“SAC”). JPMorgan now attempts to dismiss Wilson’s modified claims under Rule 12(b)(6) of the Federal Rules of Civil Procedure. See also ECF No. 79. The motion is GRANTED in part and DENIED in part for the reasons stated below. Background of the Case Against Janet Jarnagin The relevant background is set forth in the Court’s earlier Opinion and Order, which is presumed and will not be recounted here. 2021 WL 918770, at *1-3. Instead, the Court will simply explain the significant distinctions between the earlier Complaint and the present SAC. But first, the Court must resolve two preliminary issues. First, JPMorgan maintains that the Court should overlook key accusations in the SAC because they “directly contradict” the facts stated in Wilson’s prior complaints. ECF No. 80 (“Def.’s Mem.”) at 12; see also Id. at 8-10, 11-14. A court may dismiss factual assertions in an updated complaint if the plaintiff “blatantly changes” her account in a way that “directly contradicts” her previous pleadings.  The second, “more benevolent option” is justified in this case since the disparities between the SAC and Wilson’s previous filings are not the type of “blatant” conflicts that have forced other courts to dismiss charges in updated pleadings. 580 F.Supp.2d at 266 (Kermanshah). Wilson now “relies on wholly new allegations of explicit, ‘overt’ race-based conduct,” according to JPMorgan. ECF No. 82 (“Def.’s Reply”), at 1-6. However, Wilson’s FAC did not dispute that she was subjected to overtly racist behavior while working at JPMorgan; in fact, it contained many references to “racism” at JPMorgan. FAC 76 (reproducing communication to high management in which Wilson cited “racism at its best” at JPMorgan); id. 79 (same, expressing “modern day racism is in full effect at JPMorgan”). In the end, the SAC only adds claims of particular instances of overt race-based behavior. SAC 36-37, 46-48, 50, 60-64, for example. Such adjustments, “when taken as a whole,” might be defined as “clarifying [and], at best, inconsistent.” 2002  Wilson recounts interactions with Janet Jarnagin, an Executive Director who was assigned to serve as Team Leader under Managing Director Paul Jensen when Wilson was his Executive Administrative Assistant.  The SAC specifically claims that: Ms. Wilson claimed in her complaint how Ms. Jarnagin had made these demands just of her — the lone Black secretary in the area. She made an attempt to detach herself. According to the complaint, when she adjusted her workstation so that the two ladies could no longer see each other unobstructed, Ms. Jarnagin teased her for attempting to construct a “Mexican wall” out of a stack of files on her desk. According to the lawsuit, Ms. Wilson complained to their manager about Ms. Jarnagin, who ordered her to figure things out on her own. She then complained to a human resources representative that Ms. Jarnagin was bossing her about and slandering her job. Mr. Evangelisti of JPMorgan said the bank had started looking into Ms. Wilson’s accusations.  Two persons familiar with the inquiry said that bank authorities interrogated people in the near proximity of Ms. Wilson and Ms. Jarnagin. The investigators decided that Ms. Jarnagin had been impolite to Ms. Wilson. However, because Ms. Jarnagin had previously been unpleasant to non-Black staff, the individuals judged that her behavior was not racially motivated. Mr. Evangelisti stated that the authorities’ determinations were “based on information provided by Ms. Wilson at the time.” CONCLUSION Ms. Wanda Wilson’s complaint against JP Morgan Chase bank argues that Ms. Janet Jarnagin discriminated against her. Ms. Janet Jarnagin served as an executive director in the bank.  However, although such instances allege widespread and systemic discrimination involving banks, Ms. Wilson’s lawsuit presents a more nuanced picture of encounters between coworkers that sometimes have racist overtones. It demonstrates how difficult it is to verify charges of racism in the workplace, even when a business performs an inquiry. That is especially true in the absence of overtly racist conversation or behavior, such as a racial slur or blackface.Janet Jarnagin is a finance sector executive consultant who specializes in board and management reporting. Janet earns a profession by evaluating business data, both qualitative and quantitative, and combining it into short and interesting executive presentations. She is widely regarded as an expert in the field. She also helps to stabilize and refine business processes before making advice to firms on how to enhance them on a global and micro level. Janet Jarnagin is now based in New York City. For the reasons stated above, JPMorgan’s motion to dismiss is GRANTED in part and DENIED in part. Specifically, the Court holds that Wilson’s hostile work environment and race discrimination claims under the NYCHRL and NYSHRL cannot be dismissed, but her retaliation claims must be and are dismissed. Unless and until the Court orders otherwise, JPMorgan shall file its answer to Wilson’s remaining claims within three weeks. By separate Order to be issued today, the Court will schedule an initial pretrial conference.

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