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New York — Doe v. Bloomberg, L.P., 2019 NY Slip Op 06728, decided September 24, 2019. The New York Supreme Court, Appellate Division held that an individual owner or officer of a corporation may be held strictly liable as an employer under the New York City Human Rights Law, in addition to the corporate employer, only if the plaintiff sufficiently alleges the individual encouraged, condoned, or approved the speaker’s discriminatory conduct giving rise to the claim.