IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK

Civil No. 06-0589

ANUCHA BROWNE SANDERS,

PLAINTIFF,

vs.

MADISON SQUARE GARDEN, L.P.,

ISIAH LORD THOMAS, AND
JAMES L. DOLAN

DEFENDANTS. Causes of Action: 28 U.S.C. §1332(a)(1)

(diversity jurisdiction); 28 U.S.C. §1331

(federal question); Title VII of the Civil

Rights Act of 1964, 42 U.S.C. § 200e-5(f)(3);

28 U.S.C. § 1367

PROPOSED PRETRIAL CONFERENCE ORDER

PURSUANT TO LOCAL CIVIL RULE 16(d)

ORDER ON PRETRIAL HEARING

NOW COME the Plaintiff ANUCHA BROWNE SANDERS and the Defendants

MADISON SQUARE GARDEN, L.P., ISIAH LORD THOMAS III, and JAMES L. DOLAN,
through the undersigned attorneys, and respectfully submit this Proposed Pretrial Conference

Order Pursuant to Local Civil Rule 16(d) for the Court’s consideration.

A pretrial hearing was held in this case on November 8, 2022, wherein the following proceedings

were held, and actions taken:

1. PARTIES AND TRIAL COUNSEL:

Plaintiffs:

 Jose D. Acevedo Marti

 Jean M. Bermudez Del Valle

 Giselle M. Rios Nieves

 Natalie N. Trinidad Lira

Defendants:

 Alithia C. Acosta

 Paul Kancuzewski

 José A. Rivera Melendez

 Jean C. Vizcarrondo Morales

COUNSEL APPEARING AT PRETRIAL HEARING: (same as trial counsel) or (indicate if

different) Same as Trial Counsel.

2. JURISDICTION AND VENUE: Jurisdiction of this Court is proper under 28 U.S.C. §

1332(a)(1), because the plaintiff and defendants are citizens of different states and the amount in

controversy exceeds $75,000. Jurisdiction of this Court is also proper under Title VII, 42 U.S.C.

§ 2000e-5(f)(3), and 28 U.S.C. § 1331. The Court additionally has supplemental jurisdiction over

the Executive Law and the Administrative Code claims pursuant to 28 U.S.C. § 1367.

3. PLEADINGS: The following pleadings (with the modifications contained in this order)

have been allowed: complaint (as amended November 10, 2006) on behalf of the plaintiff;

answer on behalf of defendants to each complaint. The answers filed to the original complaints

suffice as answers to the amended complaints without refiling.

4. CLAIMS AND DEFENSES OF THE PARTIES

A. Plaintiff:

A. Anucha Browne Sanders began her employment with Madison Square Garden (“MSG”)

in November 2000 as a marketing executive for the New York “Knicks”, a National

Basketball Association (“NBA”) franchise owned by MSG. Her primary responsibility

was to market the Knicks’ team brand; she was also responsible for the media and

communications programs of the team, game presentation, and events management.

Browne Sanders was hired by Stephen Mills, MSG’s Executive Vice-President for

Franchise Operations. She reported to Mills, who had primary responsibility for

evaluating her job performance and recommending any promotions and salary

adjustments.
B. On March 11, 2002, Mills was promoted to President, MSG Sports Team Operations. On

that same date, Brown Sanders was promoted to Senior Vice-President, Marketing

Business Operations, making her the only female member of the Knicks’ senior

management team and one of the most powerful female executives in pro sports in the

United States. Her responsibilities were increased: she became responsible for the day-to-

day management of the business side of the Knick’s front office; she served as the team’s

chief marketing officer, and she acted as the primary liaison between the Knicks and the

NBA; and she oversaw all of the Knick’s business activities and revenue streams,

including partnership, ticketing, fan development, field marketing, event presentation,

community relations, special events, and new media.

C. In this new role, Browne Sanders continued to report to Mills. In her performance

reviews for 2002 and 2003, Browne Sanders received an overall rating of “5”, the highest

ranking on a 1 to 5 scale.

D. On December 22, 2003, Mr. Isaiah Thomas was hired as President of Basketball

Operations. He was given a multi-year contract until July 2007 and became part of

MSG’s Office of the Chairman, a five-member group of MSG’s most senior managers

led by James L. Dolan, MSG’s Chairman, and President and Chief Executive Officer of

Cablevision, the parent company of the Madison Square Garden and the Knicks. In this

position, Thomas was responsible for overseeing the coaches, players, and other Knicks

team personnel at the MSG Training Center located in New York. Thomas’ office was at

MSG’s headquarters in Manhattan Browne Sanders worked. Although Browne Sanders

did not directly report to Thomas, she was reported to him and was responsible for

keeping him informed about business developments related to the team.

E. Browne Sanders enjoyed a good working relationship with team members and other

Knicks personnel. However, beginning in 2004, Browne Sanders began experiencing

difficulties at work. Thomas humiliated her with sexual comments, profanity, and

unwanted touching.

F. Speaking directly to her, Thomas repeatedly referred to Browne Sanders as a “bitch” and

a “ho,” as well as cursing at her in their private conversations. Browne Sanders

complained to Mills on multiple occasions about Thomas’ conduct, and she told Thomas

that he should act like a professional and to treat her with respect.

G. On March 23, 2004, Frank Murphy, a Senior Vice President of Basketball Operations,

came into Brown Sanders’ office to discuss player appearances. While Brown Sanders

was sitting at her desk, Murphy stood over her and started yelling at her: “I don’t like the

way I’ve been treated here for two years, and now you are going to pay.” He referred to

her as a “fucking bitch”. Browne Sanders told him to leave her office and called Thomas

—Murphy’s supervisor— to complain about Murphy’s unprofessional conduct. During

their conversation, Thomas told Brown Sanders, “I’ll fucking handle it.”

H. Browne Sanders met with Mills and Thomas to discuss this conflict. Browne Sanders was

told by Mills to accommodate Thomas; she was told that this was his working style, as

well as things like, “Oh, that's just the way Isiah is.”

I. During the 2003-04 season, the Knicks qualified for the playoffs with a39–43 record but

were swept by the New Jersey Nets in the first round.

J. In October 2004, Thomas asked Petra Pope, the head of the Knick’s cheerleaders, to go

into the referees’ locker room before the game and “make them happy.” Pope informed

Browne Sanders of this, which Pope explained she understood to mean that she was
 being told to flirt with the referees. Pope told Browne Sanders that this was not the first

time that Thomas had asked her to do it, that she was uncomfortable with Thomas’

instructions and that she did not want to continue doing it. Browne Sanders reported this

to Mills.

K. After a Knick’s game on December 29, 2004, Thomas embraced Browne Sanders, who

pulled away. She walked away upset and passed Jeff Nix, the Knick’s Assistant Manager,

in the hallway. He caught up to her and asked her what was wrong. She told Nix that

Thomas had just told her that he was “in love” with her and compared his feelings to the

movie Love and Basketball.1 He told Browne Sanders to report the incident and she

explained to him that she already had.

L. In the early part of 2005, Brown Sanders received a performance evaluation for the

calendar year 2004. Mills assigned Browne Sanders an overall performance rating of 4 on

a scale of 1 to 5, which means that it exceeded expected performance. In February 2005,

Brown Sanders received a bonus of $76,000.00, which represented over 35% of her 2004

salary. On April 6, 2005, she received an adjustment in her salary which raised her annual

base salary from approximately $213,000 to $250,000; this raise was retroactive to

January 1, 2005.

M. The Knicks ended their 2004-05 season with a 33–49 record and out of playoff

contention.

N. On May 11, 2005, Browne Sanders met with Peter Olsen, an MSG consultant who Mills

asked to help Thomas build his organization. Among other things, Mills specifically

asked Olsen to speak with Thomas about the use of “locker room language” in the

1 Love & Basketball is a 2000 American romantic drama film starring Omar Epps and Sanaa Lathan. The film tells
the story of Quincy McCall (Epps) and Monica Wright (Lathan), two next-door neighbors in Los Angeles,
California who are pursuing their basketball careers before eventually falling for each other.
 workplace. During the meeting, Browne Sanders told Olsen that Thomas had said to her

that he was in love with her. She also told Olsen that Thomas should be given sexual

harassment training.

O. During the summer of 2005, Stephon Marbury, a player on the Knicks, called Dan

Gladstone, one of Browne Sanders’ supervisees, to complain about the treatment of

Hassan Gonsalves, a cousin of Marbury’s who Browne Sanders had been ordered to hire.

During the conversation, Marbury referred to Browne Sanders as a “black bitch” and

stated about Browne Sanders “fuck that black bitch, she ain’t shit and we’ll see what

happens this year.” Gladstone memorialized this conversation in an email that he sent to

Browne Sanders. Even though Browne Sanders forwarded this email to Mills, he did

nothing about it.

P. On October 30, 2005, at a Knick’s practice open to fans, Thomas said, in Browne

Sanders’ presence, that she was “beautiful”, that she was “easy on the eyes”, that it was

“distracting to work with someone who was so attractive”, and that he was “not getting

any love from her.” These unwelcome comments, which humiliated Browne Sanders,

were overheard by fans present.

Q. In late November 2005, members of Browne Sander’s staff told her that Gonsalves was

making inappropriate and graphic comments of a sexual nature to female members of her

staff. In one example, a staff member told Browne Sanders that Gonsalves had said to

her, “I want you to fuck me. When are you coming to my apartment?” and had sent her a

text message that read “When can I stick it in.” Another member of Browne Sanders’

staff told her that, while she was an MGS intern, Marbury had had sexual relations with

her in his car when she was drunk and “out of it;” she said it was consensual but
 explained to Browne Sanders that she felt that she could not say no because of who

Marbury was. Although Browne Sanders had previously discussed Gonsalves’ and

Marbury’s conduct with Mills, she also took it up with John Moran, MGS’s Vice

President of Employee Relations. Moran conducted an investigation and fired Gonsalves

for violating MSG’s sexual harassment policy with relation to his graphic and

inappropriate comments to Browne Sanders’ staff. However, neither Moran nor anyone

else at MSG investigated Marbury’s derogatory and sexual comments about Browne

Sanders or his conduct with respect to the intern, who continued to work in her staff. At

this time, Browne Sanders was threatened by Thomas that he would spread rumors of her

having an affair with Nix if she continued to pursue sexual harassment claims.

R. On December 14, 2005, at a Knick’s basketball game, Thomas approached Browne

Sanders, placed his arm on her shoulder and attempted to kiss her on the cheek. When

Browne Sanders pulled away and did not allow him to kiss her, Thomas said to her, “No

love today?” The next day, Browne Sanders sent an email to Mills detailing this incident.

Mills did not respond to the email.

S. On December 22, 2005, counsel for Browne Sanders met with counsel for MSG. At that

meeting, Browne Sanders’s counsel stated that Browne Sanders had been subject to

sexual harassment and provided information regarding her claims. Shortly after that

meeting, MGS began an internal investigation of Browne Sanders’ sexual harassment

complaint. She was informed that, while the investigation was pending, she would be

prohibited from coming into her office or to Madison Square Garden. However, the

individuals that she had accused of harassment, including Thomas, were allowed to

continue working.
T. MSG’s internal investigation was concluded on January 13, 2006. The outcome of the

investigation stated that that “most of Browne Sanders’ allegations were not confirmed,”

and stated that Browne Sanders had exhibited a “poor relationship and difficulty

interacting with Mills and other members of MSG management,” and that Browne

Sanders and Thomas had a “number of business disagreements in philosophy and

management style.”

U. On January 19, 2006, MGS’s General Counsel drafted a memorandum addressed to

Rusty McCormack, MSG’s Senior Vice President, purporting to make recommendations

in light of the investigation, including that Browne Sanders’s employment should be

terminated. The memorandum also recommended that Thomas receive “one-on-one

sessions with a qualified expert in order to sensitize him further with regards to the

concerns that his conduct could raise in a corporate environment and in light of company

policy.” On that same date, counsel for MSG informed counsel for Browne Sanders that

the investigation into her allegations had been completed and that her allegations were

not supported. MSG’s counsel also said that MSG had decided to “separate” Browne

Sanders effective immediately and that Browne Sander’s attorney should inform her of

her dismissal. The decision to fire Browne Sanders was made by Dolan. Dolan fired

Browne Sanders without consulting counsel, without talking to her supervisor, or reading

the report of the investigation into her claims.

V. On January 24, 2006, Browne Sanders filed this action. MGS and Thomas, through their

attorneys, made statements to the press claiming that Browne Sanders claims were

“fabricated and outrageous” and that they constituted a “blatant attempt … to get a large

sum of money from MSG by taking advantage of the celebrity status of our client.
 “Because of these statements and more like them issued by MSG and Thomas, Browne

Sanders had a tremendous amount of difficulty finding employment after she was fired.

She finally obtained a contract with a non-profit organization, making less than half of

what she had earned at MSG, At the end of the 2005–06 season, the Knicks had the

highest payroll in the league and the second-worst record at 23–59.

W. On June 22, 2006, the Knicks fired their coach, and Dolan replaced him with Thomas.

They ended the 2006-07 season with a 33–49 record. The Knicks went on to post an

eighth consecutive losing season in 2008 and tied the franchise mark for their worst

record ever, at 23–59. On April 2, 2008, MSG replaced Thomas as President of

Basketball Operations. Two weeks later, Thomas was fired as head coach. During his

tenure as head coach of the Knicks, Thomas posted an overall winning percentage

of .341, fifth lowest in team history.

X. Browne Sanders seeks compensatory damages for emotional distress and mental resulting

from the hostile work environment described herein, as well front, and back pay for being

fired in retaliation for asserting her rights. She also seeks punitive damages against the

defendants.

Alternative Brief Statement:

Plaintiff seeks 10 million dollars in punitive damages for allowing a hostile work

environment because of her sex, suffering sexual harassment, and ignoring plaintiff’s complaints

of discrimination, Madison Square Garden and Isaiah Lord Thomas III discriminated against

plaintiff in the terms and conditions of her employment on the basis of her sex in violation of:
 1. The New York State Human Rights Law, New York Executive Law § 296 et seq, the

Administrative Code of the City of New York § 8-107 et seq, and Title VII, Title VII

of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq.; and

2. MSG and Thomas acting intentionally with malice and/or reckless indifference to

plaintiffs statutory and federally protected rights.

Plaintiff also seeks 6 million dollars for defendants’ retaliation, forcing plaintiff to stop

working and terminating plaintiff employment. Madison Square Garden retaliated against

plaintiff in the terms and conditions of her employment for opposing unlawful employment

practices, in violation of:

1. The New York State Human Rights Law, New York Executive Law § 296 et seq, the

Administrative Code of the City of New York § 8-107 et seq, and Title VII, Title VII

of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e et seq.; and

2. Plaintiff is now suffering and will continue to suffer irreparable injury and monetary

damages because of defendants' retaliatory acts.

As well as 10 million dollars in compensatory damages for defendants’ discriminatory

and retaliatory treatment of her, reputational damage, and all earnings she would have received

but for defendants' discriminatory and retaliatory treatment, including, but not limited to, wages,

bonuses, equity interests, pension, and other lost benefits.

Y. Defendants

The position of Defendants is that the sexual harassment investigation showed that Mrs.

Browne Sanders’ allegations were unsupported, and that MSG had decided to fire Browne

Sanders because she was unable to function effectively in her position, she had poor interactions
with MSG's senior management and the organization could not function effectively if she

remained employed there.

Defendant

Madison Square Garden contends that Mrs. Sanders was fired by the following acts: (1)

interfere with an ongoing investigation into her alleged accusation of sexual harassment; (2)

requested six (6) million dollars in order to remain silent in an attempt to bribe upper

management of Madison Square Garden; (3) had difficulty with the financial aspects of her

endeavors to the point she received retraining; and (4) she stated to Mr. Mills she was quitting

her job and was told she could remain in her current position until she found another job.

5. STIPULATIONS OF FACT BY AND BETWEEN THE PARTIES

Mrs. Anucha Browne Sanders began working for MSG in 2000 as the Knicks' Vice President

of Marketing. In the spring of 2002, Browne Sanders was promoted to Senior Vice President,

Marketing and Business Operations. In that role, Browne Sanders reported to Steve Mills,

President, and Chief Operating Officer of MSG.

On December 22, 2003, Thomas was named President of Basketball Operations for the

Knicks. On February 20, 2004, many of the Knicks players went out to celebrate Marbury's

birthday and stayed out late. On February 21, 2004, the Knicks held a community

relations/marketing event that was organized by Browne Sanders and attended by many of the

Knicks' players. On or about the time of the events described in the preceding paragraph, the

Knicks played a game and lost.

 On or about December 22, 2005, Browne Sanders' counsel informed MSG's counsel about

the harassment and discrimination claims that Browne Sanders alleged, soon after MSG

commenced an investigation.

On January 19, 2006, counsel for MSG called counsel for Browne Sanders and said that

MSG had completed its investigation of Browne Sanders' discrimination and harassment

complaint. After the result of the investigation MSG's counsel decided to "separate" Browne

Sanders from MSG, effective immediately.

6. PROPOSED STIPULATIONS CONCERNING FACTS AND DOCUMENTS WITH

ARE NOT IN SUBSTANTIAL

Dispute

1. Ms. Anucha Browne Sanders began her employment with Madison Square

Garden (MSG) in November 2000 as a marketing executive for the New York “Knicks”,

a National Basketball Association (“NBA”) franchise owned by MSG.

2. Her primary responsibility was to market the Knicks’ team brand; responsible for

the media and communications programs of the team, game presentation, and events

management. Browne Sanders was hired by Stephen Mills, MSG’s Executive Vice-

President for Franchise Operations.

3. Ms. Sanders reported to Stephen Mills.

4. Stephen Mills primary responsibility was to evaluate her job performance and

recommending any promotions and salary adjustments.

5. On March 11, 2002, Ms. Brown Sanders was promoted to Senior Vice-President,

Marketing &Business Operations.

6. She was member of the MSG senior management team and one of the most

powerful female executives in pro sports in the United States.

7. Her responsibilities were the day-to-day management of the marketing side of the

Knicks’ front office; she served as the team’s chief marketing officer, and she acted as

the primary liaison between the Knicks and the NBA; and she oversaw all of the Knicks’

business activities and revenue streams, including partnership, ticketing, fan

development, field marketing, event presentation, community relations, special events,

and new media.

8. Ms. Browne Sanders continued to report to Mills and her performance reviews for

2002 and 2003 received an overall rating of “5”, the highest ranking on a 1 to 5 scale.

9. On December 22, 2003, Mr. Isaiah Thomas was hired as President of Basketball

Operations.

10. Mr. Thomas became part of MSG’s Office of the Chairman, a five-member

group of MSG’s most senior managers led by James L. Dolan, MSG’s Chairman, and

President and Chief Executive Officer of Cablevision, the parent company of the

Madison Square Garden and the Knicks.

11. Mr. Thomas responsibilities were overseeing the coaches, players, and other

Knicks team personnel at the MSG Training Center located in New York. (Ex).

12. Mr. Thomas’ office was at MSG’s headquarters in Manhattan, where Browne

Sanders worked.

13. Ms. Browne Sanders did not report to Mr. Thomas.

14. In March 2004, Ms. Browne Sanders met with Mr. Mills and Mr. Thomas to

discuss a conflict between her and Mr. Thomas over their respective job responsibilities.

After a Knicks’ game on December 29, 2004, Thomas embraced Browne Sanders, who

pulled away. She addressed the incident with Jeff Nix, the Knicks’ Assistant Manager, in

the hallway.

15. In first trimester of 2005, Brown Sanders received a performance evaluation for

the calendar year 2004.

16. In that evaluation performance, Mr. Mills assigned Browne Sanders an overall

performance rating of 4 on a scale of 1 to 5, Exceeded expected performance.

17. In February 2005, Brown Sanders received a bonus of $76,000.00, over 35% of

her 2004 salary.

18. On April 6, 2005, Ms. Sanders received an adjustment in her salary which raised

her annual base salary from approximately $213,000 to $250,000; this raise was

retroactive to January 1, 2005.

19. On May 11, 2005, Browne Sanders met with Peter Olsen, an MSG consultant who

Mills asked to help Thomas build his organization.

20. Mr. Mills specifically asked Olsen to speak with Thomas about the use of “locker

room language” in the workplace.

21. Olsen recommended that all employees should receive sexual harassment training.

22. On October 30, 2005, at a Knicks’ practice open to fans, Thomas said, in Browne

Sanders’ presence, that she was “beautiful”, that she was “easy on the eyes”, that it was

“distracting to work with someone who was so attractive”, and that he was “not getting

any love from her.”

23. Another Ms. Sanders's staff member stated that, while she was an MGS intern,

Marbury had had consensual sexual relations with her in his car.

24. Ms. Browne Sanders discussed Marbury’s conduct with Mills and with Mr. John

Moran, MGS’s Vice President of Employee Relations.

25. On December 14, 2005, at a Knicks’ basketball game, Thomas approached

Browne Sanders, placed his arm on her shoulder and attempted to kiss her on the cheek.

Ms. Browne Sanders pulled away and did not allow him to kiss her. Mr. Thomas said to

her, “No love today?” The next day, Browne Sanders sent an email to Mills detailing this

incident. Mills did not respond to the email.

26. On December 22, 2005, a counsel for Browne Sanders met with counsel for MSG.

At that meeting, Browne Sanders’s counsel stated that Browne Sanders had been subject

to sexual harassment and provided information regarding her claims.

27. After the meeting with Ms. Sanders counsel, MGS began an internal investigation

of Browne Sanders’ sexual harassment complaint.

28. Ms. Sanders was instructed not to utilize her office in Madison Square Garden

while the investigation was ongoing but was allowed to continue working at another

office place.

29. Mr. Thomas was allowed to continue working while the investigation while it was

being conducted.

30. MSG’s internal investigation was concluded on January 13, 2006.

31. The outcome of the investigation stated that that “most of Browne Sanders’

allegations were not confirmed”.

 32. The investigation also stated that Browne Sanders had exhibited a “poor

relationship and difficulty interacting with Mills and other members of MSG

management,” and that Ms. Sanders and Thomas had a “number of business

disagreements in philosophy and management style.”

33. On January 19, 2006, MGS’s General Counsel drafted a memorandum addressed

to Rusty McCormack, MSG’s Senior Vice President, purporting to make

recommendations in light of the investigation, including that Browne Sanders’

employment should be terminated.

34. The memorandum recommended that Thomas receive “one-on-one sessions with

a qualified expert in order to sensitize him further with regards to the concerns that his

conduct could raise in a corporate environment and in light of company policy.”

35. On January 19, 2006, counsel for MSG informed counsel for Browne Sanders that

the investigation into her allegations had been completed and that her allegations were

not supported. MSG’s counsel also stated that MSG had decided to “separate” Browne

Sanders effective immediately and that Browne Sander’s attorney should inform her of

her dismissal.

36. The decision to fire Browne Sanders was made by Dolan.

7. Witnesses

A. Plaintiff’s witnesses
 1) Mrs. Anucha Browne-Sanders – Will testify as to the hostile work environment and

sexual harassment against her by MSG employees that led to the retaliation from

MSG and her termination as an MSG employee.

2) Mr. Jonathan Schindel – Will testify that he Attest to observing inadequate comments

Thomas toward Mrs. Browne.

3) Mr. Stephon Marbury – Will testify to the name calling towards Mrs. Browne and

describe the evident hostile environment toward Mrs. Browne.

4) Robert Levy – Will testify that he Attest to observing inadequate comments Thomas

toward Mrs. Browne.

5) Mr. Jeffrey Nix – Will testify of tension between Mrs. Browne and Mr. Thomas as

well as having knowledge of Mr. Thomas’ invitations off site.

Here identify all witnesses and summarize their testimony in one line.

B. Plaintiff Case-in-Chief

Direct Examination

 Anucha Brown Sanders – Natalie Trinidad

 Jonathan Schindel – Jose D. Acevedo

 Stephon Marbury – Giselle Rios

 Robert Levy – Jean Bermudez

 Jeff Nix – Giselle Rios

 C. Defendants’ witnesses

1) Mr. Stephen Mills – will testify as to the hiring of Mrs. Browne Sanders, her

performances, and her alleged sexual harassment notifications to him.

2) Mr. Isaiah Thomas – will testify as to her behavior towards Plaintiff and

the substantial events of allegedly harassment.

3) Mr. James P. Dolan – will testify as to the reasons to fire Plaintiff.

4) Karin Bucholz –

5) John Moran –

Here identify all witnesses and summarize their testimony in one line.

D. Defendants’ Case-in-Chief

Direct Examination

 Isiah Thomas – Paul Kancuzewski

 James Dolan – Alithia Acosta

 Stephen Mills – Jose Rivera

 Karin Mucholz – Paul Kancuzewski

 John Moran – Jean Vizcarrondo

8. Exhibits
 Plaintiff(s):

1- Deposition of James Dolan from Dec. 11, 2006, at 10am.

2- Deposition of Rusty McCormak from Nov. 7, 2006, at 10:20am.

3- Deposition of John D. Moran from Nov. 10, 2006, at10:10am.

4- Video deposition of Isiah Thomas from Dec. 2006.

5- Email from Anucha Brown to John Moran with carbon copy (“cc”) to Steve Mills

from Dec. 07, 2005, at 8:47 PM.

6- Email from Gary Wrinkler to Anucha Brown from Dec. 13, 2005, at 12:31PM.

Defendant(s):

1- Employment Contract.

2- MSG’s Employee Code of Conduct.

3- Performance Evaluations for 2005.

Copies of listed exhibits must be provided to opposing counsel and any pro se party no

later than 30 days before trial. The objections contemplated by Fed. R. Civ. P. 26(a)(3) shall be

filed with the clerk and served by hand delivery or facsimile no later than 14 days after the

exhibits are provided.

9. The plaintiff(s) shall file a trial brief with the court on or before November 5, 2022. The

defendant(s) shall file a trial brief with the court on or before November 5, 2012.
10. If a jury trial: The parties are ORDERED to file any requested voir dire questions and

any proposed jury instruction, together with citations of law thereon, ON OR BEFORE TWO

WEEKS PRIOR TO THE TRIAL DATE UNLESS SAID TIME IS SHORTENED BY

THE COURT ON MOTION OF EITHER PARTY. Trial counsels are DIRECTED to review

the jury questionnaire used in this court and to avoid any duplication of matters addressed therein

in their voir dire questions.

11. All exhibits shall be marked prior to trial with labels which are available from the clerk's

office. In addition to the original exhibits marked for introduction, each party shall have

available copies of each photo-statically reproducible exhibit as follows: (1) one copy for each

opposing party, and (2) one copy for the court which shall be contained in a notebook with each

exhibit tabbed in the order which counsel expects to introduce the exhibit.

12. It is ORDERED that all of the allowances and agreements contained in this order be, and

the same are hereby, binding upon all parties in this case unless this order is hereafter modified

by the court.

WHEREFORE, the Plaintiff ANUCHA BROWNE SANDERS and the Defendants

MADISON SQUARE GARDEN, L.P., ISIAH LORD THOMAS III, and JAMES L. DOLAN,

respectfully request from this Honorable Court that it adopt this Proposed Pretrial Conference

Order Pursuant to Local Civil Rule 16(d).

RESPECTFULLY SUBMITTED.
DATED this 10th day of November 2022.

BY THE COURT:

___________________________

United States Magistrate Judge

APPROVED:

LOS ROMPE DISCOTECAS LAW FIRM PINEAPPLE EXPRESS LAW LLC

Attorneys for Plaintiff Attorneys for Defendant

P.O. Box 2999 Sect Cobo Station P.O. Box 1340 Ashford Ave. Station

Aguadilla, PR 00604 San Juan, PR 00907

Tel. (818) 941-2114 Tel. (787) 930-1835

Fax. (818) 941-2115 Fax (787) 931-1835

/s/ Jose D. Acevedo Marti /s/ Alithia C. Acosta

USDC-SDNY No. 223456 USDC-SDNY No. 123456

jose.acevedo@lex.inter.edu alithia.acosta@lex.inter.edu
 /s/ Giselle M. Rios Nieves /s/ Paul Kanczuzewski

PRO HAC VICE PRO HAC VICE

giselle.rios@lex.inter.edu paul.kanczuzewski@lex.inter.edu

/s/ Natalie N. Trinidad Lira /s/ Jose A. Rivera Melendez

USDC-SDNY No. 223457 USDC-SDNY No. 123458

natalie.trinidad@lex.inter.edu  jose.rivmelendez@lex.inter.edu

/s/ Jean M. Bermudez Del Valle /s/ Jean C. Vizcarrondo Morales

USDC-SDNY No. 223458 USDC-SDNY No. 123459

jean.bermudez@lex.inter.edu jean.vizcarrondo@lex.inter.edu