The instant action is a last ditch effort by plaintiff VALERIE GUSTAFF [GUSTAFF] to sue for damages as a result of alleged sexual harassment, wrongful employment termination and discrimination in violation of Executive Law § 296 (part of New York States "Human Rights Law"). Defendant MONARCH STAFFING, INC. [MSI] moves, pursuant to CPLR Rules 3211 (a) (1), (a) (5), (a) (8) and (a) (10), to dismiss plaintiffs complaint with prejudice against MSI for: failure to state a cause of action and lack of personal jurisdiction over MSI; and, for reasonable attorneys fees and costs. Plaintiff on August 21, 2008 filed the summons and on August 22, 2008 the amended complaint in this matter with the office of the Kings County Clerk. Defendant MSI filed the instant motion on September 3, 2008 with the office of the Kings County Clerk.
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