Blackrock Whistleblower

CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO.
INDEX NO. UNASSIGNED

NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 05/17/2024
SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
HAMDAN AZHAR,
Plaintiff. Index Number:
v. VERIFIED COMPLAINT
BLACKROCK INC,
DR. TIFFANY PERKINS-MUNN,
RIAZ HAKKIM,
ABC CORPS. 1-10 and
JOHN and JANE DOES 1-10,
Defendants.
PRELIMINARY STATEMENT
Hamdan Azhar is a data science leader with over 14 years of experience. He has worked various
firms, ranging from startups to large corporations, taught university courses, delivered numerous
lectures, and is a co-inventor on Facebook’s granted patent for emoji machine learning.
Hamdan joined BlackRock in February 2020, driven by its foundational principles and
commitment to being faithful stewards of the retirement assets of millions of working class
Americans. He was passionate about taking “emotional ownership”, “helping people build a
better tomorrow,” and doing so “sustainably and responsibly.”
At BlackRock, Hamdan quickly gained recognition for his innovation. He developed a powerful
search engine, Trend Spotter, analyzing data from millions of client conversations dating back to
1990. His monthly bulletins on topics including investments in China, Bitcoin, and the Federal
Reserve were read by thousands of employees.
However, in his final months at BlackRock, Hamdan uncovered self-dealing, corruption, and
conflicts of interest that contradicted BlackRock’s lofty principles. In February 2022, his boss,
Dr. Tiffany Perkins-Munn, resigned, followed by her superior, Chief Marketing Officer Frank
Cooper. Under the interim leadership of Riaz Hakkim, Hamdan was abruptly ordered to shut
This is a copy of a pleading filed electronically pursuant to1 New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 1 of 42
CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED
down Trend Spotter and transfer his projects over to Rightpoint, a company that had received $2
million from BlackRock despite its technology being criticized as “vaporware.” Hamdan also
learned that Rightpoint was Perkins-Munn’s husband’s company – her husband, Damien Scott,
had worked there for over 10 years and was their managing director in charge of their financial
services business, something no one at BlackRock had known.
Hamdan refused to endorse the extension of Rightpoint’s contract due to the conflict of interest.
Believing the actions of Perkins-Munn and Hakkim were illegal, Hamdan raised concerns and
threatened to file a complaint. In retaliation, and just days before he was set to begin a
prestigious new role at BlackRock AI Labs, Hamdan was wrongfully terminated, causing deep
trauma and ending his career in asset management.
By standing up for what was right, Hamdan honored his dedication to being a principled
technologist and a faithful employee, motivated by a firm personal and professional ethical code.
One year after his termination, Congress opened an investigation into BlackRock for illegal
investments in blacklisted Chinese companies with links to human rights abuses.
This complaint is not just a plea for redress for Hamdan but an attempt to bring transparency and
accountability to the world’s largest asset manager and combat corporate malfeasance on Wall
Street.
I. THE PARTIES
1. Mr. Azhar is a former employee of BlackRock, residing in New York.

2. Defendant BlackRock Inc. (“BlackRock”) is an American multinational corporation based
in New York, deriving substantial revenue from interstate commerce.
3. Defendant Dr. Tiffany Perkins-Munn was a Managing Director at BlackRock for over four
years and is now Managing Director at JPMorgan Chase & Co., residing in New Jersey.
Former BlackRock Managing Director, Dr. Tiffany Perkins-Munn

4. Defendant Riaz Hakkim was a Director at BlackRock for over four years and is now Vice
President at Fidelity Investments, residing in New York.
Former BlackRock Director, Riaz Hakkim

5. During the relevant period, Defendants ABC Corps. 1-10 are currently unknown entities
who employed Plaintiff or aided and/ or abetted in the commission of conduct
complained of herein. As the parties engage in discovery, Plaintiff retains the right to
amend the Complaint to add these entities or individuals by name.
6. During the relevant period, Defendants John and Jane Does 1-10 are currently unknown
individuals and/or employees who aided and/or abetted in the commission of conduct
complained of herein and/or who either acted within the scope of their employment.
Defendants ratified, embraced and added to this conduct. As parties engage in discovery,
Plaintiff retains the right to amend the Complaint to add these individual employees by
name.
II. JURISDICTION AND VENUE

7. This Court has jurisdiction pursuant to C.P.L.R. § 3119(e).
8. Venue in the County of New York is proper pursuant to C.P.L.R. § 503(a) because one or
more of the parties has a place of business located in the City of New York.
9. This Court also has subject matter jurisdiction under New York Labor Law § 740,
commonly known as the “New York Whistleblower Law”, which prohibits retaliatory
action against an employee who “discloses, or threatens to disclose to a supervisor or to a
public body an activity, policy or practice of the employer that the employee reasonably
believes is in violation of law, rule or regulation.” The Law also prohibits retaliatory action
against an employee who “objects to, or refuses to participate in any such activity, policy
or practice.”
III. FACTUAL ALLEGATIONS

10. Mr. Azhar grew up in Brooklyn, New York, and is the son of first-generation immigrants
from Pakistan, and is a product of the New York City public school system.
11. Mr. Azhar graduated from the Bronx High School of Science in 2003.
12. Mr. Azhar earned a B.S. in Economics from Penn State University in 2007 and an M.S. in
Biostatistics from the University of Michigan in 2010.
13. Mr. Azhar was also a Ph.D. student in Neuroscience at the University of Chicago from
2010 to 2011.
14. From 2011 to 2019, Mr. Azhar had a distinguished career in data science and analytics in
the technology and finance industries at firms including GraphScience, Facebook,
PRISMOJI, and Blockchain Technologies Corporation.
15. Mr. Azhar also worked as a Senior Consultant on Ron Paul’s 2012 Presidential Campaign
and was a Founding Member of Bitcoin Center NYC, the world’s first brick-and-mortar
bitcoin exchange, which opened in 2013.
16. Mr. Azhar has also been an activist and leader in the Muslim-American community for
over two decades, and co-founded the Muslim Writers Collective in 2014, one of the
largest and longest running open mics in the United States.
17. While at Facebook, Mr. Azhar did seminal work on emoji machine learning and is one of
four co-inventors on Facebook’s granted patent in this field1.
18. In addition to Mr. Azhar’s technology career, he has been a freelance journalist since
2002, and has published over 30 articles on politics, technology, and culture in leading
outlets including Wired, Forbes, VICE, the Washington Post, and the Christian Science
Monitor, among other outlets2.
19. Mr. Azhar has been passionate about using journalism to promote accountability and
expose wrongdoing for the entirety of his career. For example, in 2019, Mr. Azhar
published a headline story in Wired about politicians sharing sensitive individual data on
political contributions with Facebook3.
20. Mr. Azhar has also been a prolific public speaker on technology and culture and has
delivered over 40 invited talks in 14 countries since 2015, including at TEDx and Google,
and at universities including Boston University, Columbia University, Cornell University,
Penn State University, the University of Pennsylvania, and the University of Washington,
among others4.
Background
21. Mr. Azhar joined BlackRock on February 3, 2020, as Vice President and Head of Data
Science for Global Marketing.
22. Mr. Azhar was hired by Defendant Tiffany Perkins-Munn, Managing Director, who was
then head of the Research, Analytics, and Data team ("RAD") in Global Marketing.
23. Mr. Azhar’s role was initially intended to report to Defendant Riaz Hakkim. However, by
the end of Mr. Azhar’s first week at the firm, Defendant Perkins-Munn that he should
report directly to her.
24. On February 19, 2020, Defendant Perkins-Munn sent an email to all of Marketing,
stating: “We are excited to announce that Hamdan Azhar has joined the Research,
Analytics & Data team, based in NYC and reporting into Tiffany Perkins-Munn. Hamdan
1
U.S. Patent No. 10,546,015 B2 (issued Jan. 28, 2020). <https://patents.google.com/patent/US10546015B2>
2
Publications, Hamdan Azhar (2023). <http://www.hamdanazhar.com/publications.html>
3
Politicians Don't Trust Facebook—Unless They're Campaigning, WIRED (2019).
<https://www.wired.com/story/facebook-privacy-candidates-pixel-campaigning>
4
Speaking, Hamdan Azhar (2023) <http://www.hamdanazhar.com/speaking.html>
will lead the Data Science pillar of the team, focusing on incorporating Big Data tools
and technologies into our analytical strategies.”
25. From 2020 through 2022, Mr. Azhar was head of the RAD Data Science pillar while
Defendant Hakkim was the head of the RAD Data & Infrastructure pillar, and they both
reported directly to Defendant Perkins-Munn. The size of Mr. Azhar’s team ranged from
one to four data scientists during this time period.
26. Mr. Azhar’s annual year end rating for 2020 was "Strongly Performed" and his annual
year end rating for 2021 was "Achieves Most Expectations."
27. Mr. Azhar was never put on any performance improvement plans nor did he ever receive
any written reprimands or warnings throughout his tenure at BlackRock.
28. Mr. Azhar’s base salary when he joined was $157,500 per year, and as of May 18, 2022,
it was $190,000 per year, due to two performance-based year-end increases and a one-
time firmwide base salary increase.
29. Mr. Azhar’s annual bonus for 2020 was $50,000 and his annual bonus for 2021 was
$40,000.
30. Mr. Azhar was routinely celebrated as a rising star and up and coming technology leader
and innovator by senior leaders throughout the firm.
31. In June 2020, Mr. Azhar founded the BlackRock Data Science & Analytics Community,
for the first time, connecting 20+ data science and analytics teams from across the firm.
32. In December 2020, Mr. Azhar organized the BlackRock Natural Language Processing
Symposium, with 40+ speakers and 1,000+ attendees over two days, at the time, the
largest firmwide knowledge sharing event in the history of the firm.
33. In December 2021, Mr. Azhar organized the BlackRock Innovation Forum, with 120+
speakers and 800 attendees over three days, setting the new record for the largest
firmwide knowledge sharing event in the history of the firm.
34. The event was closed out by Rob Goldstein, BlackRock Chief Operating Officer, Senior
Managing Director, and member of the BlackRock Global Executive Committee, whom
Mr. Azhar personally interviewed in a 45 minute fireside chat on the future of innovation
at BlackRock.
35. In the fireside chat, Goldstein told Mr. Azhar, that he “had to personally come and meet
the people who loved BlackRock so much that they would be sitting in the office at 5pm
in the second week of December during a pandemic to connect the whole firm.”
36. An article prominently featuring Mr. Azhar called "Sharing in the Future of Innovation: A
Glimpse into BlackRock’s 2021 Innovation Forum" was published on BlackRock’s
website on April 22, 2022, and remains there to this day5.
37. Mr. Azhar was routinely asked by BlackRock to speak on behalf of BlackRock about data
science and analytics, and often give keynote addresses, at no less than 7
industry conferences during his tenure at BlackRock.
June 2020
38. Marketing at BlackRock had historically been siloed and disconnected across the firm’s
different businesses. The technology underpinning Marketing was rudimentary and
lagged behind the rest of the firm.
39. In 2017, BlackRock centralized 8 different marketing teams under the aegis of a new
division called Global Marketing and hired Frank Cooper from Buzzfeed to be the new
Global Chief Marketing Officer.
40. In 2018, Cooper elevated Defendant Perkins-Munn to lead Research, Analytics, and Data
for Global Marketing. Perkins-Munn had ambitious goals for Marketing, seeking to
transform it into a center of influence and locus of power within BlackRock.
41. Meanwhile, Marketing was largely dismissed by the rest of the firm. The perception was
that Cooper’s real job was to be a friendly face of a powerful (and largely disliked)
corporation and to improve public perception of the BlackRock brand by talking up
concepts like ESG (“Environmental, social, and governance”) and “stories of social
good”.
42. Against this backdrop, and with the goal of securing large budget and headcount
allocations for their team, Defendants Perkins-Munn and Hakkim convinced Cooper to
approve a $2 million contract with the consulting firm Accenture.
5
Sharing in the Future of Innovation: A Glimpse into BlackRock’s 2021 Innovation Forum, BlackRock (April 22,
2022). <https://careers.BlackRock.com/2022/04/22/category1/BlackRock-2021-innovation-forum>
43. The Accenture engagement was underway in February 2020 when Mr. Azhar joined
BlackRock and the stated goal was to catalyze a “Data Driven Marketing”
Transformation for BlackRock.
44. By June, the Accenture money had run out, the only product they had delivered was a
PowerPoint presentation, and the engagement was widely perceived as having been a
waste of money and a misallocation of BlackRock funds.
45. Accenture had also promised to provide a “knowledge base” consisting of their
recordings of hundreds of hours of interviews with dozens of BlackRock leaders,
executives, and technologists, employees but it was later revealed that Accenture had
accidentally destroyed those recordings without delivering them to BlackRock.
46. By June, Defendants Perkins-Munn and Hakkim had a new proposal, this time, to hire a
vendor to build a set of reporting dashboards for Marketing.
47. Cooper approved the proposal and Defendants Perkins-Munn and Hakkim arranged for
six different vendors to submit bids in what was supposed to be a competitive process.
48. In June 2020, Defendants Perkins-Munn and Hakkim announced that they had decided on
three finalists – Rightpoint, Slalom Consulting, and Publicis Sapient. They asked the
RAD Leadership Team to rate the vendors based on a standard rubric they had created
(e.g. “Vision”, “Qualifications”, “Cost Effectiveness”, etc.)
49. Rightpoint is a division of Genpact, a professional services firm legally domiciled in
Bermuda and founded in New Delhi, while Slalom Consulting is an American company
headquartered in Seattle, and Publicis Sapient is an independent American subsidiary of
the Publicis Groupe and is headquartered in Boston.
50. Rightpoint had no previous relationship with BlackRock, while Slalom and Digitas
Sapient both had existing master services agreements (“MSAs”) with BlackRock.
51. The guidance from BlackRock’s Sourcing and Vendor Management team had always
been to prioritize vendors who already had MSAs with BlackRock to avoid the costly and
lengthy diligence and compliance processes that were necessary to onboard new vendors.
52. Based on the ratings submitted by the five members of the RAD Leadership Team,
Rightpoint did not have the highest average ratings nor did they submit the lowest bid.
53. However, in a meeting to discuss vendor selection, Defendant Perkins-Munn announced

at the last minute that she and Defendant Hakkim were adding a new category to the
rubric they had shared earlier, called ESG (“Environmental, social, and governance”).
54. Defendant Perkins-Munn told the RAD Leadership Team that because Rightpoint’s
presentation had been given by an African-American woman, they had earned the highest
score ESG, and because ESG was a BlackRock priority, she and Defendant Hakkim had
decided to award the contract to Rightpoint.
55. Mr. Azhar does not recall seeing this woman from Rightpoint ever again and cannot
recall her being involved in the Rightpoint engagement henceforth in any meaningful
way.
56. Mr. Azhar personally rated Rightpoint last due to his concerns about their lack of
qualifications for the project.
57. At the time, Defendant Perkins-Munn’s husband, Damien Scott, was a Managing Director
and Head of the New York office of Rightpoint, a role he had held since April 2020, and
continues to hold to this day.
58. Scott’s LinkedIn page describes his role at Rightpoint as “member of executive
leadership, responsible for leading Rightpoint’s global expansion and growth in the NY
metropolitan area.”
59. Scott is also featured prominently on Rightpoint’s website as a member of their executive
team and their “Head of Financial Services, Insurance, and Professional Services.”
Damien Scott, Rightpoint Managing Director and Head of Financial Services, Insurance, and
Professional Services
60. Scott joined Rightpoint in April 2020, just two months before Rightpoint would submit a
multimillion dollar bid to BlackRock and sign a contract directly with his wife’s team.
61. Prior to that, since 2012, Scott had held executive positions at TandemSeven, another
firm under Genpact, Rightpoint’s parent company.
62. At no point in time did Defendant Perkins-Munn ever disclose to the RAD Leadership
Team that her husband was a senior executive at Rightpoint, the same firm to which she
would eventually award $2 million in BlackRock contracts.
63. At no point in time was this self-dealing and conflict of interest – that Defendant Perkins-
Munn was awarding a multi-million-dollar contract to her husband’s company - ever
disclosed to BlackRock Legal and Compliance.
64. In fact, a senior member of BlackRock Legal and Compliance informed Mr. Azhar that
Defendant Perkins-Munn’s failure to disclose this conflict of interest would have been
grounds for termination had it been uncovered.
65. Had Mr. Azhar been aware of Defendant Perkins-Munn’s conflict of interest at the time in
June 2020, Mr. Azhar would have immediately raised concerns with BlackRock Legal
and Compliance. As detailed below, Mr. Azhar raised his concerns upon discovering this
conflict of interest.
66. BlackRock has five core principles as part of its mission statement. The first principle is:
“We are a fiduciary to our clients. Our clients’ interests come first.6” BlackRock CEO
Larry Fink routinely repeats this both publicly and internally. BlackRock’s clients are the
millions of hard working Americans, including firefighters, teachers, and nurses, whose
retirement savings and pensions BlackRock manages.
67. Throughout his career, Mr. Azhar upheld the principle of acting in the best interests of
clients. When he encountered what he reasonably believed to be illegal and unethical
behaviors, such as self-dealing and misappropriation of BlackRock funds, he felt a
personal duty to speak up against these actions to protect the interests of millions of
hardworking Americans.
6
The BlackRock principles, BlackRock (accessed May 16, 2024). <https://www.blackrock.com/corporate/about-
us/mission-and-principles>
10New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

This is a copy of a pleading filed electronically pursuant to
October 2020
68. Defendants Perkins-Munn and Hakkim signed a master services agreement and statement
of work with Rightpoint on October 26 in the amount of $437,799.
69. Over the next 19 months, subsequent statement of works would be signed for an
additional $1,500,000.
70. The suite of marketing dashboards built by Rightpoint would come to be called ONYX.
January 2021
71. Mr. Azhar’s year-end rating for 2020 was “Strongly Performed” and his year-end bonus
was $50,000, $10,000 higher than the “target bonus” he had been promised when he
joined.
72. Defendant Perkins-Munn informed Mr. Azhar this was due to his exceptionally strong
performance the previous year. The verbal review she delivered was overwhelmingly
positive.
73. Defendant Perkins-Munn did not submit a written year-end review for Mr. Azhar in
Workday despite repeated and multiple requests by Mr. Azhar over the subsequent 9
months.
74. Upon Mr. Azhar’s repeated inquiries, Defendant Perkins-Munn informed him that she
had verbally told him his rating and that he had been given a higher-than-expected bonus,
and that the written review was just a formality that she would eventually get to.
75. Mr. Azhar was later informed that a manager’s failure to submit a written year-end review
for a direct report should have been reported to Human Resources and Legal and
Compliance and constitutes misconduct.
February 2021
76. Mr. Azhar’s understanding of his core job description had always been to use his data
science subject matter expertise to ensure technical rigor in everything the team worked
on.
77. Defendant Perkins-Munn would routinely pull Mr. Azhar into meetings with vendors and
explicitly instruct him to “ask them hard questions” and “make sure they know their
stuff.”

78. Most notably, this happened in February 2021 with a vendor named Storyful, whom
defendants were paying hundreds of thousands of dollars for reports on social media
sentiment about BlackRock.
79. Defendant Perkins-Munn directed Mr. Azhar and Candace Whye-Jacobs, then Vice
President, to audit Storyful’s data and they found widespread irregularities.
80. Whye-Jacobs and Mr. Azhar presented their results of their audit to Storyful in February
2021 and in a follow-up workshop, Storyful walked the BlackRock Marketing team line
by line through their data. After that meeting, the universal consensus was that Storyful’s
data was unreliable and that their sentiment algorithm was inaccurate more than 80% of
the time, something that Storyful acknowledged as well.
81. Mr. Azhar was praised for being a faithful steward and watchdog of BlackRock’s
resources. As a result of that meeting, Defendant Perkins-Munn stopped paying Storyful
from the RAD cost center, and the costs of the Storyful contract were taken over by the
Brand Strategy team, a separate team within Global Marketing.
June – July 2021

82. On June 9, Defendant Perkins-Munn and Mr. Azhar were interviewed at the Business of
Data Festival about their careers and their experiences in data science and analytics in
industry. Perkins-Munn was effusive in her praise of Mr. Azhar and referred to him as a
“rock star” on her team7.
83. After Mr. Azhar posted on LinkedIn about his ethos of “inspiring with data”, Frank
Cooper, BlackRock Chief Marketing Officer, Senior Managing Director, and member of
the BlackRock Global Executive Committee commented on Mr. Azhar’s post, “Hamdan
— I love the notion of inspiring with data! Thanks for sharing your thoughts on building
a data driven culture.”
84. Starting in June, Mr. Azhar began to have concerns about operational risks posed by the
Rightpoint engagement and the ONYX project. Throughout the summer, he raised these
concerns with both Defendants Perkins-Munn and Hakkim.
7
The Insights are Right! | Journey to the Data Driven Enterprise, Business of Data: Corinium Global Intelligence
(June 9, 2021) <https://www.youtube.com/watch?v=HvCicETMoBo>

85. For example, in one email on June 30, 2021, addressed to Defendant Perkins-Munn and
Whye-Jacobs, Mr. Azhar raised the concern that “At the end of the engagement,
Rightpoint will have accumulated a lot of institutional knowledge about BlackRock that
will leave with them, as there is no information or data transfer mechanism to the rest of
RAD or the rest of BLK.”
86. In another email on July 14, 2021, addressed to both Defendants Perkins-Munn and
Hakkim, Mr. Azhar suggested escalating to the Legal and Compliance or Sourcing and
Vendor Management teams, writing: “A few of our team members have voiced similar
concerns to me and have suggested another option could be to loop in SVM or Legal
since this is a significant risk and control issue for BlackRock – to have an external
vendor collecting some of our most sensitive data and leaving nothing to show for a $1m
engagement except a set of dashboards and a few wiki pages.”
87. On July 21, 2021, Mr. Azhar scheduled a meeting with Defendants Perkins-Munn and
Hakkim as well as Whye-Jacobs and Jimmy Choi, then Vice President and now Director,
with the following in the body of the invite: “My goal for this call is to align on an
information archival and transparency protocol through which everything Rightpoint
does is rigorously documented and all materials relating to this engagement – including
but not limited to meeting notes, documents, decks, datasets, Excel files, recordings of
meetings – from the past, present, and in the future, are in a shared location that is
updated regularly that anyone in RAD can easily access.”
88. Defendant Perkins-Munn acknowledged the concern when she replied all to the invite, on
the same day, “Thanks for pointing out this operational risk! This is an important
consideration for all of our development work!”
89. During that meeting, Mr. Azhar again raised concerns of the operational risks posed by
the Rightpoint engagement and the ONYX project.
September 2021
90. After Mr. Azhar had escalated to BlackRock Human Resources multiple times his
concerns that Defendant Perkins-Munn still had not entered his 2020 year-end review
into Workday, Perkins-Munn finally emailed Mr. Azhar his review which she had
rewritten from memory since she claimed she could not find her notes. It was

substantially different from and had a completely different tone than the overwhelmingly
positive review she delivered verbally to him in January.
91. It is now Mr. Azhar’s belief that this was in direct and illegal retaliation for Mr. Azhar
raising concerns about the BlackRock contract with her husband’s company, Rightpoint,
and for threatening to report those concerns to BlackRock Legal and Compliance
throughout the summer.
December 2021
92. In parallel with Defendant Hakkim’s work with Rightpoint, Mr. Azhar had been given a
$200,000 budget to partner with another vendor, Slalom Consulting, to build an alternate
set of data products that Mr. Azhar had spearheaded and designed, called Whole Client
View and Trend Spotter.
93. The goal of these products was to, for the first time, centralize and standardize all of
BlackRock’s client data into one easily accessible data product that anyone at BlackRock
could access. (Prior to this, client data was distributed across multiple legacy databases
and servers that were disconnected, difficult to access, and devoid of any standardized
naming conventions.)
94. Mr. Azhar’s team completed building Whole Client View and Trend Spotter in December
after three months, ahead of schedule and under budget, and this generated a great deal of
buzz within the firm.
95. It is Mr. Azhar’s belief that Defendant Hakkim was worried that these products would
overshadow his work on the ONYX project in partnership with Rightpoint, which was
over budget, over timeline, and had limited usage and adoption.
96. As such, as Mr. Azhar continued to raise concerns about the problems with the ONYX
project, shortly after Defendant Perkins-Munn departed, Defendant Hakkim began a
steady campaign of targeted retaliation, intimidation and bullying directed against Mr.
Azhar.
Trend Spotter
97. Trend Spotter, conceived and designed by Mr. Azhar, began as a BlackRock hackathon
project in March 2021. It was modeled after Google Search Trends and built on top of
tens of millions of BlackRock’s “sales activity notes”, dating back to 1990, which were

entered by BlackRock client relationship managers and sales staff into various databases
after meetings with clients. (Prior to Trend Spotter, these notes were locked in difficult to
access, legacy databases and stored in on-premises servers in Delaware.)
98. Trend Spotter, in its final version, had two core functionalities: “trending topics” and
“note search”.
99. The “trending topics” functionality applied natural language processing (NLP) to the
notes to extract key themes and topics using tokenization, lexical analysis, n-gram
analysis, and topic modelling.
100. After extracting the key themes and topics, Trend Spotter would then quantify how often
these themes and topics were mentioning in the notes, both for the current time period, as
well as for historical periods.
101. Trend Spotter would then surface to the user the most frequently mentioned themes and
topics in the current period, as well as the themes and topics that were “trending”, that is,
those that had increased most significantly in prevalence in the current time period. For
example, a user might open Trend Spotter and see that in the current week, “Omicron”,
“Emerging Market Debt”, and “Infrastructure” were the most common themes and topics
in the notes, and that Emerging Market Debt was mentioned in 8% of the notes, and that
this was up 25% month-over-month and 50% year-over-year.
102. Marketing teams could then use these insights to create custom promotional materials on
Emerging Market Debt, and Sales teams could use these insights in client conversations
as a means of promoting BlackRock’s thought leadership in keeping a pulse on what was
top of mind for BlackRock clients and for investors.
103. The second core functionality of Trend Spotter was “note search” which enabled a user to
enter a search term, such as China, and see summary data tables and visualizations
displaying metrics on how many client conversations had mentioned China in the most
recent week, as well as metrics on what types of clients were mentioning China (e.g. 50%
sovereign wealth funds, 30% pension funds, 10% hedge funds, 10% insurance
companies), as well as their geographic locations.
104. “Note search” also enabled a user to read the actual notes mentioning a given search
term. For example, a search for China might yield 100s of notes, and a user would see
excerpts of the sentences mentioning China, with China highlighted, such as “Spoke with

Rob on Tuesday, he mentioned PIF interested in buying $20M of Emerging Market Debt,
especially from China, will call him back next week with proposal.”
105. Trend Spotter received widespread attention and acclaim from within BlackRock, and
over the course of several months, Mr. Azhar was invited to demo Trend Spotter to over a
dozen of BlackRock’s highest profile teams, including BlackRock Investment Institute,
the Financial Modeling Group, Institutional Client Business, the Portfolio Analytics
Group, Portfolio Management Group, Strategic Partner Program, the U.S. Wealth
Advisory Business, Aladdin, and iShares, as well as senior leaders across functions like
sales, marketing, product, and engineering.
106. Mr. Azhar’s team also circulated monthly bulletins, reaching thousands of BlackRock
employees, about key themes in client conversations that they had identified using Trend
Spotter, and some of the most common themes during this time period were China,
Bitcoin, and the Federal Reserve.
107. As a journalist, Mr. Azhar is and was aware of Title 15-Commerce and Foreign Trades,
Part 744-Control Policy: Supplemental No. 4 to Part 744-Entity List ("U.S. Blacklist").
The U.S. Blacklist prohibits American capital flows to Chinese companies that the U.S.
government has blacklisted because of their role in fueling the People’s Republic of
China’s (PRC) military advancement or in facilitating the Chinese Communist Party’s
(CCP) human rights abuses.
108. Mr. Azhar informed his manager of the importance of the Trend Spotter platform that he
had created and the fact that it could monitor client discussions about illegal investments
in Chinese companies. He also raised concerns with his manager about whether Trend
Spotter’s revelations about investments in Chinese companies aligned with BlackRock’s
public disclosures and representations to shareholders, investors, and federal regulators.
He raised concerns that any discrepancies or irregularities could be unlawful.
109. Mr. Azhar’s concerns were ignored, and ultimately, he was directed to shut down Trend
Spotter in March 2022.
110. It is Mr. Azhar’s belief that building Trend Spotter and raising aforementioned concerns
could have put him on the radar at BlackRock and contributed to the retaliatory and
adverse actions he later experienced.

111. In August 2023, Congress opened an investigation into illegal activities by BlackRock
and facilitation of capital flows into Chinese military enterprises implicated in human
rights abuses against Uyghur Muslims.
112. Mr. Azhar believed he was directed to shut down Trend Spotter to cover up evidence of
illegal and unethical activities, that had previously been buried on servers in Delaware,
and as a result of his work, were now made accessible and searchable to any employee at
BlackRock – as well as potentially to Congress and federal investigators.
January 2022
113. Mr. Azhar’s year-end rating for 2021 was “Achieves Most Expectations” and his year-end
bonus was $40,000. Defendant Perkins-Munn submitted a year-end review for Mr. Azhar
in Workday which contained substantial misstatements and irregularities. Mr. Azhar’s
intention was to dispute these with Human Resources.
114. Mr. Azhar believes that Defendant Perkins-Munn entered these defamatory statements
into his year-end review in illegal retaliation for the concerns he was raising about
BlackRock’s $2 million contract with her husband’s company and for the work his team
was doing to publicize BlackRock client mentions of investments in Chinese companies
through Trend Spotter.
February 8, 2022
115. Defendant Perkins-Munn abruptly announced that she had submitted her resignation from
BlackRock to Frank Cooper, BlackRock Chief Marketing Officer, Senior Managing
Director, and member of the BlackRock Global Executive Committee.
116. She informed the team that that her last day would be March 31 and that she was
considering two opportunities, one in consumer finance in New York, and one in
technology in London. (Months later, her LinkedIn was updated to reflect that she had
joined JP Morgan Chase & Co. in June 2022 as Managing Director and Head of
Marketing Data & Analytics.)
117. Defendant Perkins-Munn informed Mr. Azhar that he would report to Defendant Hakkim
in the interim until her replacement was hired.

February 28, 2022

118. Defendant Perkins-Munn informed Mr. Azhar that Frank Cooper had just resigned. (On
March 2, 2022, Visa announced that they had hired Cooper as Global Chief Marketing
Officer.)
March 8, 2022
119. Defendant Hakkim announced at the weekly data science sync that upon the instructions
of Alex Craddock, then interim BlackRock Chief Marketing Officer and Managing
Director, and current Chief Marketing and Content Officer at Citi, and senior BlackRock
leadership, Hakkim was officially directing Mr. Azhar to cease all work on Trend Spotter.
120. Mr. Azhar informed Defendant Hakkim afterwards in their 1:1 meeting that TrendSpotter
was continuing to generate widespread interest from senior leaders across the firm and
had the potential to uncover crucial intelligence from client conversations, including
mentions of illegal investments in Chinese companies, but Defendant Hakkim was
unmoved. “Alex wants us to shut it down right away,” he said.
March 15, 2022

121. Mr. Azhar met Kevin Ahern, Vice President, who led data and digital efforts for the
Institutional Client Business (“ICB”) Marketing team. They discussed multiple possible
synergies and ideas for projects.
122. Ahern told Mr. Azhar, completely unprompted, that his team had stopped using
Rightpoint’s ONYX project because “the data was wrong” and “didn’t match their
records” and “Rightpoint was unable to help us understand why the data was wrong” and
“working with them was a waste of time.”
123. Ahern also mentioned that Di Sanborn, former head of ICB Marketing and Managing
Director, and current Head of Institutional Marketing at Coinbase, had herself been
personally upset that Defendant Hakkim was inaccurately touting ICB Marketing as a
happy customer of the ONYX project when they thought it was a “complete waste of
firm resources.”
March 22, 2022

124. Mr. Azhar had a mentorship call with Defendant Perkins-Munn during which he informed
her of his upcoming meeting with Rob Goldstein, BlackRock Chief Operating Officer,
Senior Managing Director, and member of the BlackRock Global Executive Committee
and she shared her advice for that meeting.
March 28, 2022
125. In the 6 weeks between March 28 and May 17, Mr. Azhar met with 13 of the firm’s senior
most managing directors to get their advice and guidance and brainstorm possible future
roles, including:
a. Frank Cooper, then BlackRock Chief Marketing Officer, Senior Managing
Director, and member of the BlackRock Global Executive Committee, and current
Chief Marketing Officer of Visa;
b. Salim Ramji, then Global Head of iShares and Index Investments, Senior
Managing Director, and member of the BlackRock Global Executive Committee,
and recently named CEO of Vanguard;
c. Ajar Ashyrkulova, Managing Director, Portfolio Analytics Group;
d. Dr. Andrew Ang, Managing Director, and Head of Factors, Sustainable and
Solutions for BlackRock Systematic Investing;
e. Dr. Amer Bisat, Managing Director, and Head of Emerging Markets Fixed
Income;
f. Kirsty Craig, Managing Director, Portfolio Management Group;
g. Diwakar Goel, Managing Director, and Global Head of Data;
h. Neeraj Goel, Managing Director, and Global Head of Alpha Generation
Technology;
i. Jonathan Lerner, Managing Director, and Head of Client Data Science;
j. Jabari Magnus, Managing Director, and Global Head of Portfolio Analytics
Group;
k. Stefano Pasquali, Managing Director, Financial Modeling Group;
l. Adam Salvatori, then Managing Director, and Head of Alpha Engineering and
Digital Assets Lab, and current Head of Fidelity Labs; and
m. Dr. Rachel Schutt, Managing Director, and Head of AI Labs.

126. All of them were effusive in their praise of Mr. Azhar’s contributions to BlackRock as an
up and coming technology leader and were eager to share their guidance, mentorship, and
support in helping to keep him at BlackRock and to find the best possible role for him.
127. Mr. Azhar also had meetings already scheduled and on the calendar with:
a. Woo Fung Kwong, Managing Director, and Head of Aladdin Wealth on May 18;
b. Josh Warren, then Managing Director, and Global Head of Business Strategy,
iShares and Index Investments, and current Chief Financial Officer of Envestnet
on May 19; and
c. Rob Goldstein, BlackRock Chief Operating Officer, Senior Managing Director,
and member of the BlackRock Global Executive Committee, on May 27.
128. Throughout these meetings, Mr. Azhar was feted and celebrated as a rising star at
BlackRock, and everyone was full of ideas for critical roles Mr. Azhar could play in the
future of BlackRock.
129. For example, after Mr. Azhar’s meeting with Ramji on April 22, Ramji emailed Warren
and Benjamin Elbaz, Managing Director, and Global Head of Product Management,
Aladdin, on April 29, writing “I met Hamdan last week and he was thinking about career;
he has a really interesting background in data sciences and I thought you might be
interested in meeting up with him. I really enjoyed our discussion.”
March 30, 2022

130. Mr. Azhar had his first weekly 1:1 with Defendant Hakkim in Hakkim’s capacity as Mr.
Azhar’s interim manager. Mr. Azhar informed Hakkim of his intention to leave Marketing
and find a different role at BlackRock given Defendant Perkins-Munn and Cooper’s
departure. Mr. Azhar shared with Hakkim that Mr. Azhar needed to work for a
charismatic leader who deeply understood data science, technology, and the asset
management business, and that there were very few such leaders at BlackRock.
131. Defendant Hakkim had only positive feedback about Mr. Azhar and asked him to give
him “full transparency” into names and dates of whoever he was meeting with so that he
could help him.
132. Defendant Hakkim informed Mr. Azhar that Mr. Azhar’s two priorities until he moved to
a new team should be the Attribution project that Mr. Azhar was working on with ETF

and Index Investments (“EII”) Marketing and working with Rightpoint so that they could
integrate Whole Client View, a data product that Mr. Azhar had built in 2021 with Slalom
Consulting, into the ONYX project.
133. Later this day, there was a going away party for Defendant Perkins-Munn at a bar across
the street from BlackRock headquarters at 55 East 52nd St. Eric Lachance, Vice President
at Rightpoint, and the lead of the BlackRock engagement approached Mr. Azhar and said
he looked forward to working with him on Whole Client View.
April 7, 2022
134. Mr. Azhar had his weekly 1:1 with Defendant Hakkim. Hakkim’s feedback was entirely
positive.
135. Mr. Azhar informed Defendant Hakkim of Mr. Azhar’s upcoming meeting with
Goldstein. Hakkim was visibly shaken and taken aback and asked Azhar how he was able
to get that meeting. “I have been here for three years and have never met anyone at that
level,” said Hakkim.
April 12, 2022

136. Mr. Azhar met Dr. Rachel Schutt, Managing Director, and Head of BlackRock AI Labs
and they had a fruitful discussion about a role for Mr. Azhar in BlackRock AI Labs as
COO and Head of AI Strategy for BlackRock. She informed Mr. Azhar that she had open
headcount on her team and that she had been following his successes at BlackRock
admirably for years and that Mr. Azhar would be a strong asset on her team. She
suggested they meet again to discuss what the responsibilities and scope of the role would
be.
April 19, 2022
137. Mr. Azhar had his weekly 1:1 with Defendant Hakkim. Hakkim’s feedback was entirely
positive.
138. Mr. Azhar informed Defendant Hakkim of Mr. Azhar’s positive meeting with Schutt on
April 12.
139. Mr. Azhar informed Defendant Hakkim of Mr. Azhar’s upcoming meeting with Salim
Ramji, then Global Head of iShares and Index Investments, Senior Managing Director,

and member of the BlackRock Global Executive Committee, and recently named CEO of
Vanguard. (At this time, Hakkim reported to Craddock who in turn reported to Ramji.)
140. Defendant Hakkim was surprised and asked Mr. Azhar how he was able to get the
meeting with Ramji. “I have been here for three years and have never met anyone at that
level,” said Hakkim.
141. Mr. Azhar also informed Defendant Hakkim about Mr. Azhar’s ongoing efforts to
organize BlackRock’s Muslim employees and to arrange an iftar dinner in observance of
Ramadan.
142. Mr. Azhar also informed Defendant Hakkim of the widespread concerns of junior Muslim
employees of rampant bigotry, prejudice, and Islamophobia throughout the firm and Mr.
Azhar’s passion for advocating for these junior employees with senior leadership.
143. Mr. Azhar raised concerns with Defendant Hakkim of unlawful acts of discrimination that
junior Muslim employees at BlackRock had experienced.
144. Defendant Hakkim was visibly perturbed and began to make derogatory and disparaging
comments about Mr. Azhar’s religious observances. Hakkim said: “I have never fasted, I
always get headaches. I could never focus on work while fasting, how can you do your
job while fasting? That’s weird.”
145. Defendant Hakkim is originally Indian and was raised in India. Mr. Azhar is of Pakistani
origins and was raised in New York. Mr. Azhar believes that in addition to anti-Muslim
animus, Mr. Hakkim’s subsequent adverse actions were also motivated by anti-Pakistani
animus due to Mr. Azhar’s religion and national origins.
April 20, 2022

146. Mr. Azhar met with Glenn Meyer and Michelle Spangenberg of Rightpoint to discuss
their vision for integrating Whole Client View into Rightpoint’s ONYX project.
147. After the meeting, Mr. Azhar raised concerns with Defendant Hakkim about Rightpoint,
their lack of understanding of the Whole Client View project, and the lack of
qualifications of the people they had staffed on the project.

April 25, 2022

148. In their weekly data science sync, Mr. Azhar again raised concerns with Defendant
Hakkim about Rightpoint, their lack of understanding of the Whole Client View project,
and the lack of qualifications of the people they had staffed on the project.
149. Mr. Azhar met Schutt and she reiterated her eagerness to have him join her team,
BlackRock AI Labs, as COO and Head of Strategy.
April 26, 2022

150. Mr. Azhar organized the first ever Ramadan iftar dinner for Muslim employees at
BlackRock, sponsored by the BlackRock Asian and Middle Eastern Professional
Network.
151. For many years, BlackRock had been known as a hostile place for employees of color
and Muslim and Middle Eastern employees specifically had reported being targeted and
subjected to faith-based discrimination, bullying, and retaliation.
152. For example, in February 2021, Essma Bengabsia, former analyst at BlackRock, had
gone public with allegations of racial, religious, and sexual discrimination, which had
been heavily covered in the financial press8 9.
153. The release of these allegations created a "code red" reputational crisis at the highest
levels of BlackRock leadership. Clients, including pension funds and sovereign wealth
funds, were deeply concerned about BlackRock’s hypocrisy in promoting the Governance
component of ESG while mistreating its own minority employees.
154. During Mr. Azhar’s two years at BlackRock, he had also heard from numerous junior
level minority staffers, especially Muslims and people of Middle Eastern descent, who
felt they needed to hide their identity at the workplace due to rampant bigotry, prejudice,
and Islamophobia.
155. In April 2022, for the first time in BlackRock’s history, Mr. Azhar organized the
company’s Muslim employees through a Microsoft Teams chat group. The group grew
8
BlackRock under pressure to live up to its promises on diversity, Financial Times (March 21, 2021).
<https://www.ft.com/content/6476e681-4154-43a6-93e4-f5c86ae30dd9>
9
BlackRock Responds to Former Employees’ Claims of Racial and Sexual Discrimination, Institutional Investor
(February 19, 2021). < https://www.institutionalinvestor.com/article/2bswpo28um6zpimajdq0w/culture/BlackRock-
responds-to-former-employees-claims-of-racial-and-sexual-discrimination>

rapidly over several weeks, eventually reaching nearly 100 members. Many members
expressed their gratitude to Mr. Azhar for creating the group, sharing that they had felt
demoralized and vulnerable due to rampant bigotry, prejudice, and Islamophobia within
the firm, especially at the senior levels.
156. Through the BlackRock Asian and Middle Eastern Professional Network, Mr. Azhar
connected with Dr. Amer Bisat, Managing Director and Head of Emerging Markets Fixed
Income. Mr. Azhar informed Dr. Bisat of the widespread dissatisfaction and concerns
among junior Muslim employees and his efforts to organize them and his interest in
helping channel their concerns to senior leadership to improve the situation. Mr. Azhar
raised concerns with Bisat of unlawful acts of discrimination that junior Muslim
employees at BlackRock had experienced.
157. Bisat informed Mr. Azhar that he was well aware of the rampant bigotry, prejudice, and
Islamophobia within the firm. He shared that senior leaders had directed him to placate
the concerns of Muslim employees and that he had personally tried to counsel Bengabsia
against going public with her concerns. Dr. Bisat offered to sponsor an iftar dinner for
Muslim employees.
158. The iftar dinner organized by Mr. Azhar, and sponsored by Bisat, was held in Manhattan
on April 26, 2022, and attended by Bisat, Mr. Azhar, and five junior Muslim employees.
April 27, 2022

159. In Mr. Azhar’s weekly 1:1 with Defendant Hakkim, the day after the iftar dinner, for the
first time ever, Hakkim mentioned “multiple written complaints” he had received about
Mr. Azhar from stakeholders and teammates “from a performance standpoint”, involving
“project ownership”, “knowledge base”, “communication”, and “lack of engagement and
direction.”
160. Defendant Hakkim mentioned that Rob Edelman, Director, was one of Mr. Azhar’s
stakeholders who had filed complaints against him.
161. Defendant Hakkim told Mr. Azhar that this was “very, very critical” and Mr. Azhar
should take this “very, very seriously.”
162. Mr. Azhar asked Defendant Hakkim if anyone else knew and he said “this is only
between you and me for now.”

163. Mr. Azhar asked Defendant Hakkim to see the complaints that had allegedly been filed
against him. Hakkim refused.
164. Mr. Azhar was stunned that this was happening, out of nowhere, the very day after he had
organized Muslim employees at BlackRock. “Is this because of the iftar?” Mr. Azhar
asked. Defendant Hakkim refused to answer.
165. It is Mr. Azhar’s belief that Defendant Hakkim illegally retaliated against him and
engaged in discriminatory and adverse actions and among his motivations were anti-
Muslim and anti-Pakistani animus.
April 28, 2022

166. Mr. Azhar met with Rightpoint to discuss the Whole Client View roadmap.
May 3, 2022
167. In the weekly RAD Leadership Team meeting and in the weekly data science sync, Mr.
Azhar informed Defendant Hakkim that Mr. Azhar was continuing to speak with
Rightpoint about Whole Client View and again raised concerns about their lack of
understanding of the Whole Client View project and the lack of qualifications of the
people they had staffed on the project.
168. Mr. Azhar also informed Defendant Hakkim that Scott Smith, Managing Director, and
Andrew Gidney, Managing Director, both of the Client Experience Management team
had expressed interest in Whole Client View. Mr. Azhar informed Hakkim of Mr. Azhar’s
view that the project might be a more natural fit within Smith and Gidney’s team rather
than in Marketing, and that perhaps Rightpoint should be severed from the engagement
entirely.
169. It is Mr. Azhar’s belief that Defendant Hakkim felt personally threatened by the prospect
of his project with Rightpoint being taken away from him and further being put under the
microscope due to the concerns Mr. Azhar was raising, and that Hakkim engaged in
adverse and retaliatory actions against Mr. Azhar as a result.
170. Mr. Azhar also informed Hakkim that Fergus Slinger, Managing Director, had reached
out to enlist Mr. Azhar’s help over the summer with a top-secret client data project, code
named “Hudson Yards”, sponsored directly by BlackRock’s Global Executive

Committee. “Everyone I spoke with sings your praises and speaks highly of your passion
and expertise in the area of client data,” Slinger said to Mr. Azhar.
171. In their weekly 1:1 meeting, Defendant Hakkim informed Mr. Azhar that BlackRock
Human Resources was aware of the “performance concerns” he had raised the previous
week and that “HR is internally having conversations about next steps.”
172. Mr. Azhar raised concerns to Defendant Hakkim that Mr. Azhar had not been given a
chance to view any of the issues people had allegedly reported against him nor had Mr.
Azhar been given a chance to share his perspective and point of view.
173. Mr. Azhar asked Defendant Hakkim if Mr. Azhar himself should also go to Human
Resources himself to raise his concerns that Mr. Azhar was being targeted and retaliated
against. Defendant Hakkim told Mr. Azhar “Don’t do that, don’t go to HR, let me handle
it, I will let you know what HR says.”
174. Mr. Azhar consulted a trusted advisor and mentor at the firm that same day, and he was
told: “[Defendant Hakkim] is just trying to bully you, don’t let it get to your head, focus
on starting the new role as soon as possible.”
175. Mr. Azhar informed Defendant Hakkim that all of this came as a surprise since Mr. Azhar
had a record of solid performance during his time at BlackRock. “That’s not what Tiffany
told me,” he said.
176. It is Mr. Azhar’s belief that Defendant Tiffany Perkins-Munn shared derogatory
information with Defendant Hakkim about Mr. Azhar prior to her abrupt departure from
BlackRock as part of her continued pattern of retaliation against Mr. Azhar for raising
concerns about her $2 million contract with her husband’s company.
May 4, 2022
177. Mr. Azhar emailed Schutt a first draft of a job description for the COO, Head of Strategy
role at BlackRock AI Labs.
May 5, 2022
178. Mr. Azhar met with Rightpoint to discuss the Whole Client View roadmap. They
presented a 12 week roadmap for a Product Fit Assessment.

May 6, 2022
179. Mr. Azhar met with Schutt to review the job description that Mr. Azhar had drafted for
the BlackRock AI Labs role. She had positive feedback and asked Mr. Azhar to meet with
6 senior members of her team over the next week to workshop and refine the description
while she was attending an offsite in Edinburgh.
180. These members included Raphael Benarrosh, then Vice President and current Director;
Dr. Stephen Boyd, Co-Head of BlackRock AI Labs and Professor at Stanford University;
Nan Liu, Director; Dr. Simon Lyons, Director; Alex McKay, Director, and Dr. Shawn
Simpson, Director.
181. Schutt also asked Mr. Azhar to meet with Harqs Singh, Managing Director and COO to
BlackRock CTO and Managing Director Kfir Godrich, and she informed Mr. Azhar that
Singh would provide the final sign-off for Mr. Azhar’s internal transfer to BlackRock AI
Labs as a formality and that she was excited to have him join her team.
182. Later that day, Schutt emailed her 6 team members as well as Singh, writing “[Hamdan]
and I have discussed a potential role within AI Labs that might be something along the
lines of product strategy/COO for AI Labs. I asked Hamdan to set up time to discuss with
each of you as we refine what the job description would be.”
May 9, 2022
183. In the team’s weekly data science sync, Mr. Azhar informed Defendant Hakkim that
Rightpoint had proposed a 12-week roadmap for a Product Fit Assessment. Hakkim
instructed Mr. Azhar to “get Rightpoint to reduce the 12 weeks to 8 weeks.”
184. From May 9 through May 17, Mr. Azhar had wonderful conversations with all 6 team
members of BlackRock AI Labs and there was universal excitement about Mr. Azhar
joining the team and raising the profile of AI Labs, both within the firm, and externally
within the data science, technology, and financial services industries.
May 10, 2022

185. In Mr. Azhar’s weekly 1:1 with Defendant Hakkim, Hakkim again instructed Mr. Azhar
to “get Rightpoint to reduce the 12 weeks to 8 weeks.”

186. He also directed Mr. Azhar to encourage Rightpoint to “leverage the existing body of
work Slalom had conducted in building Whole Client View to shave off time from the
roadmap.”
May 11, 2022

187. At 12:44pm, Mr. Azhar emailed the Rightpoint team to confirm his meeting with them
later that afternoon.
188. Mr. Azhar received an automatic OOO reply from Eric Lachance, the Rightpoint Vice
President who was leading the BlackRock engagement: “I will be out of the office 3/16
returning 3/17. Replies will be delayed. If this is urgent, please contact
damienscott@rightpoint.com. Thank you.”
189. Mr. Azhar did not pay any particular attention to this email at the time, and its
significance would only become evident to him later that afternoon.
190. Mr. Azhar walked across the street to the BlackRock office at 40 E. 52nd Street for his
4pm meeting with the Rightpoint team.
191. Rightpoint was onsite for a two day workshop with Defendant Hakkim and Rukmini
Prabhu, Director, to discuss the ongoing partnership between Global Marketing and
Rightpoint and what their scope of work would be going forward in 2022.
192. Mr. Azhar’s meeting with them, from 4-5pm, was intended to align on the roadmap for
Whole Client View, which would make up a significant portion of Rightpoint’s overall
2022 scope of work and corresponding budget.
193. In the meeting, Mr. Azhar was polite but firm and asked pointed questions of the
Rightpoint team to better understand the roadmap and where we could shave some time,
as per Defendant Hakkim’s instructions.
194. Mr. Azhar was also not sure who exactly from Rightpoint would be staffed on each phase
of the project. For example, they had allotted 4 weeks for a technical data assessment,
and they had indicated Glenn Meyer would be leading that. This is the type of work
usually led by data engineers. However, upon Mr. Azhar’s questioning, it became clear
that Meyer lacked any technical training and had no experience in Tableau, SQL, or
Python, so Mr. Azhar was confused how Meyer would lead a rigorous 8 week technical

assessment. (Mr. Azhar later learned that Meyer’s education consists of an M.S. in
Integrated Marketing and an M.A. in Christian Apologetics.)
195. Mr. Azhar was also confused by remarks made by Spangenberg that as part of the
assessment, they would need to deconstruct the Marketing Facts Time Series table
(“MFTST”).
196. Mr. Azhar explained to Spangenberg that the MFTST was simply a union of existing core
Marketing datasets spanning email, webinar, event, and web activities, and that
Rightpoint had been working with those core Marketing datasets for one and a half years
and should already have accumulated subject matter expertise in that data, and as such,
there would be no need for spending many weeks deconstructing the table.
197. Mr. Azhar was also confused by Rightpoint’s ability to lead a “Current State Discovery”
workstream since the current version of Whole Client View had been built in Tableau and
Spangenberg informed Mr. Azhar that “Rightpoint does not really have Tableau people.”
198. Mr. Azhar also mentioned to the Rightpoint team that many teams at the firm were
dissatisfied with their work on the ONYX project and specifically mentioned the
concerns that Ahern from ICB Marketing had raised with Mr. Azhar on March 15, 2022.
199. Spangenberg’s reaction was to strongly suggest they not partner with ICB Marketing for
Whole Client View if they were already so dissatisfied with their work.
200. Mr. Azhar was concerned about Meyer and Spangenberg’s lack of understanding of the
project, its objectives, and BlackRock.
201. Mr. Azhar encouraged the Rightpoint team to bring their A game to the project. Mr. Azhar
said: “We are in year 5 of a data driven marketing transformation and we have spent $5
million with vendors so far and we have very little to show for it. This project is our
chance to turn that around.”
202. For context, prior to the engagement with Rightpoint that Defendants Perkins-Munn and
Hakkim had spearheaded, Perkins-Munn and Hakkim had also led a multi-million dollar
“Data Driven Marketing” engagement with Accenture that had failed to deliver any
meaningful results and had been universally viewed as a failure within BlackRock, and
had even reportedly caught the attention of Gary Shedlin, then BlackRock Chief
Financial Officer and Senior Managing Director.

203. One of the key promised deliverables from the Accenture engagement was supposed to
be a knowledge base consisting of Accenture’s recordings of hundreds of hours of
interviews with dozens BlackRock leaders, executives, and technologists, but it was later
revealed that Accenture had destroyed these recordings without delivering them to
BlackRock, and all they had to show for a multimillion-dollar engagement was a
PowerPoint presentation.
204. Marketing specifically had a less than stellar reputation within BlackRock for waste, self-
dealing, and misallocation of BlackRock resources. One director said the modus operandi
of many senior executives was “jobs for your mates."
205. On another occasion, Jimmy Choi, then Vice President and now Director, informed Mr.
Azhar that: “If your team is granted a budget for a specific year, you have to fully spend
it by the end of the year, otherwise Finance will give you less money the following year.
What matters is that we spend the money, what we spend it on isn’t that important.”
206. Back to the Rightpoint meeting, despite Mr. Azhar raising concerns many times,
everyone aligned that as a next step, Meyer and Mr. Azhar would meet again the
following Monday afternoon to align on a stakeholder list and interview guide.
207. After the meeting, Mr. Azhar walked back to his desk across the street at BlackRock’s
headquarters at 55 E. 52nd Street. Upon checking his email again, it was at this moment
that Mr. Azhar put two and two together and realized that the Damien Scott mentioned in
Lachance’s out of office message had the same name as Defendant Perkins-Munn’s
husband.
208. Mr. Azhar then googled the name Damien Scott and found a picture of him on
Rightpoint’s website, captioned as “Damien Scott, Head of Financial Services, Insurance,
and Professional Services."
209. Mr. Azhar recognized the man in the picture immediately. Perkins-Munn had introduced
Scott to Mr. Azhar as her husband on February 27, 2020, at a happy hour that Accenture
had organized for BlackRock Marketing to celebrate the completion of their engagement.
210. Mr. Azhar was in shock that Defendant Perkins-Munn had signed a contract and sent $2
million in BlackRock funds to her husband’s company, blatantly and openly, when her
husband’s photograph was right there on Rightpoint’s website. And now Defendant

Hakkim wanted Mr. Azhar to endorse an extension of this contract and send untold
millions more to the same company.
211. Mr. Azhar perceived this as not only unethical and immoral, but also a fraudulent and
illegal misappropriation of millions of dollars in BlackRock assets, representing the
retirement savings of millions of working-class American firefighters, teachers, and
nurses, to a company run by the husband of a BlackRock Managing Director.
212. Mr. Azhar approached Defendant Hakkim, who had taken up residence in Perkins-
Munn’s former office, with concerns that the Rightpoint contract was fraudulent and
unlawful, and that the ONYX project was vaporware intended to defraud BlackRock.
213. Mr. Azhar also raised concerns with Defendant Hakkim that his conversation with
Rightpoint gave him déjà vu of Hakkim and Perkins-Munn’s engagement with Accenture
in 2020, which cost $2 million and yielded nothing but a PowerPoint presentation.
214. Mr. Azhar emphasized to Defendant Hakkim the need for serious due diligence to ensure
the Rightpoint engagement did not end the same way.
215. Mr. Azhar reiterated his firm belief, as a data science subject matter expert, that ONYX
had severe issues with usability, data quality, infrastructure, and product leadership. He
noted its limited usage and adoption within the firm and pointed out that the Rightpoint
team lacked the necessary skills and qualifications, posing an operational risk due to poor
documentation, subpar code, and sensitive client data.
216. Mr. Azhar informed Defendant Hakkim that Perkins-Munn’s husband was a managing
director at Rightpoint, which appeared to be a clear case of self-dealing and fraud, and
which Mr. Azhar believed was unlawful given BlackRock CEO Larry Fink’s constant
reminders that “We are a fiduciary and we always act in the best interests of our clients.”
217. Mr. Azhar informed Defendant Hakkim that he objected to and refused to endorse or
participate in an extension of Rightpoint’s contract and that he intended to file a
complaint with Legal and Compliance.
218. Defendant Hakkim seemed stunned and dazed and responded, without addressing any of
Mr. Azhar’s concerns: “I didn’t realize two years had passed already since the Accenture
engagement and since you joined.”

May 12, 2022

219. At this time, Mr. Azhar’s two main projects were Whole Client View, which Defendant
Hakkim had instructed Mr. Azhar to drive with Rightpoint, and Marketing Attribution,
which Mr. Azhar was driving with EII Marketing, specifically with Rob Edelman,
Director, Candy Danquah, Director, and Monique Le, Managing Director.
220. Edelman was Mr. Azhar’s main stakeholder on Marketing Attribution project. Since
Edelman had just joined BlackRock three months earlier, Mr. Azhar had been focused on
“showing him the ropes” and empowering him to lead the project so Mr. Edelman could
get off to a strong start and have a significant win under his belt.
221. Mr. Azhar informed Edelman about Defendant Hakkim’s allegation that Edelman had
filed a complaint against Mr. Azhar. Edelman was stunned and said that “I have only
good things to say about you.”
222. Edelman informed Mr. Azhar that Defendant Hakkim’s narrative was false and that
Edelman had never filed a complaint.
223. Edelman informed Mr. Azhar that Defendant Hakkim came to him asking for feedback on
every single member of the team, “person by person.”
224. Edelman informed Mr. Azhar that Edelman’s feedback on Mr. Azhar had been
“overwhelmingly” but that Defendant Hakkim had kept pressing: “Is there any one thing
he [Azhar] could improve on?”
225. Edelman informed Mr. Azhar, “I don’t know what Riaz’s agenda is.”
226. Mr. Azhar also had a follow up meeting with Slinger who reiterated to Mr. Azhar that he
wanted him to play a critical role in two of the highest priority workstreams of Hudson
Yards, the top-secret client data project, sponsored by BlackRock’s Global Executive
Committee, over the summer.
May 13, 2022

227. Mr. Azhar received an email from Kathleen Lukasik of Rightpoint, addressed to Mr.
Azhar, with Defendant Hakkim carbon copied, as well as Meyer and Spangenberg, in
addition to Lachance and Dara Anker, informing Mr. Azhar that “You’ll see a cancellation
come through soon for the Monday meeting on WCV [Whole Client View] next steps. As

an outcome from our working sessions the past few days, we’ll need to pause this work
for now.”
228. Starting at 12:33pm, Defendant Hakkim started sending Mr. Azhar multiple emails and
Teams messages requesting to meet immediately.
229. When they finally spoke at 4pm, Defendant Hakkim mentioned that “I needed to talk to
you about something…Rightpoint has put in a complaint about you…their leadership has
shared some feedback with me, Rukmini [Prabhu, Director], and Alex [Craddock,
Managing Director] after the discussions and two-day workshop.”
230. Defendant Hakkim said that Rightpoint had complained that during Mr. Azhar’s one hour
meeting with them on May 11, Mr. Azhar was “confrontational”, “set the wrong tone in
the meeting right away”, “spent the first 10 minutes clarifying how Rightpoint’s work is
hated among some BlackRock employees”, and “was trying to prove they are not capable
of the work.”
231. Defendant Hakkim said that the Rightpoint team felt “belittled”, that it was a “bullying
session”, and that “the junior resources in the room felt upset and demoralized.”
232. Defendant Hakkim said that “There is nothing we can do at 4:30pm on a Friday” but
mentioned that this is “very serious” and that he would follow up on next steps.
233. Mr. Azhar asked Defendant Hakkim for a copy of the complaint and Hakkim refused.
234. Immediately after Defendant Hakkim’s call, Mr. Azhar called a trusted mentor at the firm,
to relay the story to him. The mentor told him: “[Hakkim] is just trying to bully you. You
have nothing to worry about. If there was an actual vendor complaint and it’s serious,
Alex [Craddock] will come to you and give a chance to share your side of the story.” The
mentor advised Mr. Azhar to keep his head down and not make waves until he started his
new role at BlackRock AI Labs in a few days.
May 17, 2022

235. At the weekly leadership team meeting at 11am, Defendant Hakkim mentioned that his
top priority was working with Rightpoint to “drive ONYX forward” and to “come up
with the project scope and pricing model” for 2022.

236. Prabhu mentioned that she and Defendant Hakkim were considering engaging Rightpoint
for a new workstream, “MMF Strategy”, to “help standardize measurement across
various marketing teams”, in addition to the ongoing ONYX project.
237. Defendant Hakkim mentioned that “We don’t have a lot of budget left for Rightpoint to
engage both initiatives” and reiterated that his top priority was getting more budget
approved for Rightpoint.
238. Stephen Whitten, Director, raised concerns about the Rightpoint engagement: “If the
biggest challenge is getting senior buy in, why are we hiring an outside consultant? Why
aren’t we doing this ourselves?”
239. Mr. Azhar also raised concerns about the Rightpoint engagement.
240. At 3:43pm, Mr. Azhar received a calendar invite from Defendant Hakkim to join an
8:30am meeting the following morning with the subject line “Follow-up on Feedback.”
May 18, 2022

241. When Mr. Azhar joined the meeting at 8:30am, Defendant Hakkim was present as well as
Sue Pino, Vice President, from Human Resources.
242. Defendant Hakkim and Pino informed Mr. Azhar that his employment at BlackRock was
being terminated effective immediately and that his systems access would be cut off at
the end of that meeting.
243. Defendant Hakkim mentioned that this was because of the complaint filed against Mr.
Azhar by Rightpoint.
244. Defendant Hakkim also mentioned that he had received feedback about “interpersonal
communications” and “leadership on projects” and said that “Marketing leadership has
given this a lot of thought” and “We feel that you lack the understanding of the potential
reputational damage and loss of vendor partnership” that had led them to “question your
judgement.”
245. Defendant Hakkim mentioned that “We were planning to issue you a performance
improvement plan” but “based on the severity of the feedback” from the meeting Mr.
Azhar had with Rightpoint on May 11th, “we made the decision to terminate your
employment effective today.”

246. Defendant Hakkim informed Mr. Azhar that Alex Craddock, interim Chief Marketing
Officer of BlackRock, had personally signed off on the termination.
247. Pino reinforced Defendant Hakkim’s narrative, stating that their original intent had been
to issue a performance improvement plan, but that after the Rightpoint complaint, they
had decided to terminate immediately.
248. After the meeting, at 10:12am, Mr. Azhar reached out to Rob Goldstein, BlackRock Chief
Operating Officer, Senior Managing Director, and member of the BlackRock Global
Executive Committee; Manish Mehta, Senior Managing Director and then Global Head
of Human Resources; and Rachael Akohonae, Global Head of Employee Relations,
sending an email with the subject, “Raising concerns about retaliation for protected
activities.”
249. In the email, Mr. Azhar wrote: “As you know, I love BlackRock and have had a
wonderful time here, and am hopeful your team can investigate these concerns fairly and
equitably.”
250. Later that day, at 6:43pm, Akohonae responded, “We take your concerns seriously and as
such I have referred this matter to our Global Head of Investigations, Debbie Barry, and
our experienced investigator Evelyn Miller, both in copy, who will reach out to you to
schedule time to meet with you.”
251. Evelyn Miller, Vice President emailed Mr. Azhar at 11:14pm that evening requesting time
to speak to further discuss his concerns.
May 23 – 27, 2022

252. On May 23, Mr. Azhar was scheduled to meet with Harqs Singh, COO of Tech & Ops, to
get the final signoff to start his new role as COO and Head of Strategy for BlackRock AI
Labs.
253. Instead, on this day, Mr. Azhar had a two and a half hour conversation with Miller, which
was supposed to be about the concerns Mr. Azhar had raised with Mehta and Akohonae,
but instead involved Miller being combative and hostile and attacking Mr. Azhar’s
background and record at BlackRock.
254. On May 25, Mr. Azhar emailed Miller asking for more supporting documentation
regarding his rights as part of the investigative process.

255. On May 26, Miller responded asking to set up time to speak again.
256. On May 27, Mr. Azhar was originally scheduled to meet with Rob Goldstein, BlackRock
Chief Operating Officer, Senior Managing Director, and member of the BlackRock
Global Executive Committee.
257. In the weeks following his termination, numerous current and former senior leaders at
BlackRock reached out to Mr. Azhar to offer their support. Every single one of them said
they were shocked by what had happened.
258. One managing director told Mr. Azhar: “I cannot think of a single person who was
terminated immediately based on a complaint from a vendor, without any chance to see
or address the complaint.”
259. Another former managing director told Mr. Azhar: “The only situations where I have ever
seen anyone get terminated immediately is when there is major financial wrong doing
such as embezzling money from clients or insider trading, or sexual misconduct.”
260. Another former managing director told Mr. Azhar: “I have never even heard of a vendor
filing a complaint against an employee at a client.”
261. Mr. Azhar was a hard-working, loyal and faithful employee of BlackRock for almost two
and a half years. He loved his job and excelled at it. He always to put BlackRock’s
interests, and the interests of BlackRock’s clients, first, and strived to be a faithful
steward of the firm’s resources, which represented the retirement savings of millions of
hard-working Americans, and be true to the BlackRock principles.
June – August 2022

262. On June 2, Mr. Azhar emailed Miller with more supporting documentation, asking her to
please send any further questions via email.
263. Miller then went silent for two and a half months, and Mr. Azhar next heard from her on
August 15, when she wrote that “I have completed my investigation into the concerns
that you raised." However, she refused to provide any details about the outcome of the
investigation, or any actions taken as a result.

July 2023
264. Mr. Azhar learned that Congress had opened an investigation into illegal activities at
BlackRock, specifically related to BlackRock’s facilitation of American capital flows into
Chinese military companies implicated in human rights abuses of Uyghur Muslims10.
265. Mr. Azhar realized that Trend Spotter could easily have uncovered the type of evidence
that Congress was seeking and this would explain why Mr. Azhar had been asked to shut
down Trend Spotter in March 2022 and why Mr. Azhar had been terminated in May
2022.
IV. CAUSE OF ACTION

(Violation of New York Labor Law § 74011)
266. Plaintiff Azhar incorporates by reference all preceding paragraphs and re-alleges them as
if set forth fully herein.
267. New York Labor Law §740 provides in pertinent part as follows:
“Prohibitions: An employer shall not take any retaliatory action against an employee
whether or not within the scope of employee’s job duties, because such
employee…discloses or threatens to disclose to a supervisor …an activity, policy, or
practice of the employer that the employee reasonably believes is in violation of law,
rule, or regulation” or “objects to, or refuses to participate in any such activity, policy or
practice.”
268. §740 further provides that “an employee who has been the subject of a retaliatory action
in violation of this section may institute a civil action …” for the following relief:
a. the reinstatement of the employee to the same position held before the
retaliatory action … or front pay on lieu thereof;
b. the reinstatement of full fringe benefits and seniority rights;
c. the compensation for lost wages and other remuneration;
10
Letter to Larry Fink, House Select Committee on the Chinese Communist Party (July 31, 2023).
<https://selectcommitteeontheccp.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-
document/2023-07-31-letter-to-BlackRock.pdf>
11
On or about October 2021, NYS Gov. Kathy Hochul signed into law an expansion of N.Y. Lab. Law Sec. 740,
changing the statute of limitations from 1 year to 2. §740(4)(a); it now provides the parties with a right to a jury trial.
§740(4)(b); and in terms of the relief afforded under new §740, the statute now provides for a former employee to
recover front pay in lieu of reinstatement (§740(5)(b)) and for the payment of punitive damages “if the violation was
willful, malicious or wanton.” §740(5)(g).

d. the payment by the employer of reasonable costs, disbursement, and

attorneys’ fees;
e. a civil penalty of an amount not to exceed ten thousand dollars and/or,
f. the payment by the employer of punitive damages, if the violation was willful,
malicious, or wanton.
269. §740 further provides, in relevant part, that a “Retaliatory action” is “an adverse action
taken by an employer or his or her agent to discharge, threaten, penalize, or in any other
manner discriminate against any employee or former employee exercising his or her
rights under this section, including (i) adverse employment actions or threats to take such
adverse employment actions against an employee in the terms of conditions of
employment including but not limited to discharge, suspension, or demotion; (ii) actions or
threats to take such actions that would adversely impact a former employee’s current or
future employment...”
270. As detailed above, Plaintiff disclosed to his supervisors that Defendant Tiffany Perkins-
Munn’s self-dealing and conflicts of interest concerning the Rightpoint contract violated,
at the very least, the Sarbanes-Oxley Act, as it compromised the internal controls,
accurate financial disclosures, and ethical standards required by the Act.
271. Plaintiff also threatened to report Defendant Riaz Hakkim to Legal and Compliance for
his complicity in what Plaintiff reasonably believed was the unlawful and fraudulent
Rightpoint contract.
272. Plaintiff vehemently objected to and refused to participate in endorsing the Rightpoint
contract which he reasonably believed was a misappropriation of BlackRock assets and a
violation of BlackRock’s duties to be faithful stewards of the retirement assets of millions
of hard-working American firefighters, teachers, and nurses.
273. Plaintiff also disclosed to his supervisors activities of investments in Chinese companies
that he reasonably believed were in violation of the law, specifically, 15 CFR Part 744,
the Entity List ("U.S. Blacklist"). He indicated to his supervisors that BlackRock’s
investments in Chinese companies could be associated with misrepresentations to
shareholders, investors, and federal regulators regarding the Company's financial
performance, financial projections, and financial controls, thereby violating federal
securities law and regulations.

274. Plaintiff’s disclosures regarding these activities that he reasonably believed were in
violation of the law, and his objections to them and refusal to participate in them, qualify
him as a BlackRock whistleblower and entitle him to protection under §740.
275. As detailed above, in direct retaliation for Plaintiff’s complaints and his continued
perseverance in making these complaints, his advocacy for and attempts to organize other
individuals who had made complaints, and his refusal on May 11th to greenlight what he
believed was an illegal and unethical self-dealing contract between BlackRock and a
BlackRock executive’s husband’s company, and motivated by Defendant Hakkim’s fear
that Plaintiff would escalate his concerns to senior BlackRock leadership and state and
federal regulators, Defendant Riaz Hakkim terminated Mr. Azhar’s employment on May
18th.
276. Prior to his termination, Defendants retaliated against Plaintiff through actions including
to, but not limited to, forcing him to cease work on Trend Spotter and shut down the
platform.
277. After terminating him, Defendants continued to retaliate against Plaintiff by publicly
defaming him to other individuals by knowingly falsely impugning his business acumen,
his business abilities, and his integrity, by repeatedly asserting that he was unprofessional
in his dealings with Defendant Perkins-Munn’s husband’s company, Rightpoint.
278. Defendants Perkins-Munn and Hakkim’s actions in this regard are attributable to
Defendant Corporations as further retaliation under respondeat superior. These actions
are in direct contravention of the protections of §740 and 741.
279. In addition, Defendant Hakkim continued his retaliation against Plaintiff by refusing to
provide Plaintiff with equal access and protections afforded to all employees of
BlackRock. He refused to provide Plaintiff with the details of the alleged complaints
levied against him, refused to escalate Plaintiff’s concerns regarding Defendant Perkins-
Munn’s her illegal self-dealing and her contract with her husband’s company, and refused
to escalate Plaintiffs concerns surrounding BlackRock engaging in illegal investments
and the fact that Trend Spotter was capable of tracking it.
280. Finally, Defendant Hakkim knew of Plaintiff’s interviews and transfer opportunities with
other departments within BlackRock. Hakkim knew that if Plaintiff maintained his
employment with BlackRock working for an adjacent group, Plaintiff would expose

Hakkim for his failure to end the contract between BlackRock and Defendant Perkins-
Munn’s husband’s company, and possibly even for his alleged role in aiding and abetting
Defendant Perkins-Munn’s self-dealing and fraudulent contracts.
281. Defendant Hakkim also knew that Plaintiff was scheduled to meet with BlackRock COO
Rob Goldstein the very next week, and knew that with a new job in another division
secured, Plaintiff would have no reason not to reveal everything he knew directly to
Goldstein, thereby imperiling Hakkim’s career and potentially subjecting him to civil and
criminal liability.
282. Furthermore, Defendant Hakkim knew that Trend Spotter would have required
BlackRock to live up to their mission which is “to create a better financial future for our
clients.” Trend Spotter would have forced BlackRock to follow the law and make sure
that its investors were not being exposed to illegal investments in blacklisted Chinese
companies. Hakkim’s actions smack of bad faith, are clearly retaliatory, and represent
manifest disparate treatment as no other similarly situated employees have been so
harassed, publicly humiliated, or retaliated against.
283. These retaliatory acts violated New York Labor Law § 740. These violations were willful,
malicious, and wanton, intended to silence and discredit Plaintiff, a celebrated
technologist and rising star. As a direct and proximate result of these violations, Plaintiff
has suffered significant damages, including but not limited to lost wages (front and back
pay), lost fringe benefits, and significant attorneys’ fees. He has been traumatized and
forced to leave the asset management industry entirely.
WHEREFORE, Plaintiff respectfully requests judgment on this cause of action against Defendants
for compensatory damages in an amount to be determined at trial but believed to be not less than
$10 million, punitive damages in an amount to be determined at trial but believed to be not less
than $10 million, together with a $10,000 civil penalty, interest, and costs, including reasonable
attorney’s fees.

V. PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays that the Court enter judgment in her favor and against
Defendants, containing the following relief:
a. A declaratory judgment that the actions, conduct, and practices of Defendants
complained of herein violate the laws of the State of New York;
b. An award of damages against Defendants, in an amount to be determined at Trial,
plus prejudgment interest, to compensate Plaintiff for all monetary and/or
economic damages, including, but not limited to, loss of past and future income,
wages, compensation, seniority, and other benefits of employment;
c. An award of damages against Defendant, in an amount to be determined at Trial,
plus prejudgment interest, to compensate Plaintiff for all non-monetary and/or
compensatory damages, including, but not limited to, compensation for her
mental anguish, humiliation, embarrassment, stress and anxiety, emotional pain
and suffering, and emotional distress;
d. An award of punitive damages, in an amount to be determined at Trial;
e. Prejudgment interest on all amounts due;
f. An award of costs that Plaintiff has incurred in this action, including, but not
limited to, expert witness fees, as well as Plaintiff’s reasonable attorneys’ fees and
costs to the fullest extent permitted by law; and,
g. Such other and further relief as the Court may deem just and proper.
VI. JURY DEMAND

Plaintiff hereby demands a trial by jury on all issues of fact and damages stated herein, seeking
justice and vindication not only for himself as a BlackRock whistleblower, but also for the
broader community adversely impacted by the Defendants’ actions.

Dated: May 17, 2024
Respectfully submitted,
____________________
Subhan Tariq, Esq.
Attorney I.D.# 5263074
Tariq Law PC
Attorney for Plaintiff
99 Park Avenue, Suite 1100
New York, NY 10016
Telephone: (212) 804-9095
Email: subhan@tariqlaw.com


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CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO.

INDEX NO. UNASSIGNED

SUPREME COURT OF THE STATE OF NEW YORK

1. Mr. Azhar is a former employee of BlackRock, residing in New York.

Former BlackRock Managing Director, Dr. Tiffany Perkins-Munn

Former BlackRock Director, Riaz Hakkim

II. JURISDICTION AND VENUE

III. FACTUAL ALLEGATIONS

53. However, in a meeting to discuss vendor selection, Defendant Perkins-Munn announced

10New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

11New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

June – July 2021

12New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

13New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

14New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

15New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

16New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

17New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

February 28, 2022

March 15, 2022

March 22, 2022

18New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

19New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

March 30, 2022

20New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

April 12, 2022

21New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

April 20, 2022

22New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

April 25, 2022

April 26, 2022

23New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

April 27, 2022

24New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

April 28, 2022

25New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

26New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

May 10, 2022

27New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

May 11, 2022

28New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

29New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

30New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

31New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

May 12, 2022

May 13, 2022

32New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

May 17, 2022

33New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

May 18, 2022

34New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

May 23 – 27, 2022

35New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

June – August 2022

36New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

IV. CAUSE OF ACTION

37New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

d. the payment by the employer of reasonable costs, disbursement, and

38New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

39New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

40New York State court rules (22 NYCRR §202.5-b(d)(3)(i))

V. PRAYER FOR RELIEF

VI. JURY DEMAND