FOR IMMEDIATE RELEASE
New York, NY – September 9, 2025 — Eric Sanders, Esq., of The Sanders Firm, P.C., condemns what he characterizes as a pattern of retaliatory pleading targeting Retired Lieutenant Quathisha Epps—first in Thomas G. Donlon v. City of New York, et al., and now in Jamie Nardini v. City of New York, et al. In both, Sanders says, Epps’s name is misused to inject salacious, unsupported narratives into court records to smear a protected whistleblower and distract from documented command-level misconduct inside the NYPD.
“The retaliation is the RICO wasn’t just a headline—it was a diagnosis,” said Eric Sanders, Esq. “Donlon’s federal complaint dragged Epps into a supposed criminal conspiracy with allegations we view as flatly false—including a fabricated FBI search of her home.” Now, a state complaint parrots the same playbook, gratuitously labeling her a ‘girlfriend’ to a former Chief of Department Jeffrey B. Maddrey, her alleged abuser. Different dockets, same tactic: weaponize pleadings to punish a whistleblower.”
A Pattern Across Two Courts
In the Donlon RICO action (federal), Epps was cast as a participant in overtime fraud, with allegations Sanders asserts lack any evidentiary basis, including the claim that federal agents executed a search at her residence. Sanders maintains no such search ever occurred, that no criminal investigation involves Epps, and that the pleading misreads lawful time reconstruction practices as “fraud” to manufacture scandal around a known EEOC complainant and witness.
In the Nardini complaint (state), Scola inserts Epps into unrelated party-and-paperwork vignettes—one branding her as someone’s “girlfriend,” (Paragraph 81) another reducing her role to clerical routing (Paragraph 384)—irrelevant to the asserted causes of action, according to Sanders. “That isn’t fact pleading; it’s character assassination by caption,” he said. “Litigation privilege is not a license to smear.”
The Law Is Clear: Privilege Isn’t Blank Check
Sanders notes that while statements in court filings are generally privileged, New York courts limit that privilege to allegations ‘material and pertinent’ to the claims. Gratuitous personal attacks—particularly about romantic relationships—are precisely the sort of “scandalous or prejudicial matter” courts may strike under CPLR 3024(b). Repeating them without basis, he adds, risks sanctions for frivolous conduct under 22 NYCRR 130-1.1. On the federal side, FRCP 11(b)(3) demands evidentiary support (or a reasonable path to it) for factual contentions; reckless indifference to the truth is sanctionable.
The Record on Timekeeping: Don’t Criminalize the Employer’s Burden
Donlon’s theory, Sanders says, flips wage-and-hour law on its head. Under the FLSA and NYLL, the employer bears the burden to keep accurate records; when it fails, employees may reasonably reconstruct time. Courts have long permitted this to prevent employers from profiting off their own noncompliance. “Calling reconstruction ‘fraud’—especially where supervisors directed the practice—isn’t law; it’s leverage,” Sanders said. “It’s also a tell: when the facts don’t fit, they attack the whistleblower.”
Demand for Immediate Correction
The Sanders Firm, P.C., is demanding immediate amendment of the Nardini complaint to remove all references to Epps. Absent prompt correction, the firm will move to strike, seek sanctions, and pursue all available remedies, including fees and costs. With respect to the Donlon action, the firm will continue to challenge the sufficiency and veracity of the allegations, including relief under Rule 11.
“Epps is not the criminal—she is the witness. Using court filings to smear her is a retaliatory strategy, not an evidentiary one,” said Sanders. “Courts should not be props for innuendo, and lawyers who peddle it should expect consequences.”
About The Sanders Firm, P.C.
Fighting for Justice and Reform to Promote Equal Opportunity
Led by Eric Sanders, Esq., The Sanders Firm, P.C. litigates complex civil-rights and employment cases, with a focus on law-enforcement misconduct, retaliation, and systemic reform. A former NYPD officer, Mr. Sanders brings decades of experience exposing institutional abuses and securing meaningful relief for clients. The firm has recovered millions for victims and remains committed to accountability and integrity in public institutions.
Contact:
Eric Sanders, Esq.
President & Owner, The Sanders Firm, P.C.
30 Wall Street, 8th Floor, New York, NY 10005
(212) 652-2782
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Read the Donlon Federal Complaint
Read the Nardini Verified Complaint