Full opinion text
OPINION AND ORDER KENNETH M. KARAS, District Judge: Margaret Stofsky (“Plaintiff’) brings this action alleging, inter alia, discrimination and retaliation in connection with her former employment as a school psychologist in the Pawling Central School District (the “District”), seeking relief against the District and the District’s Board of Education (the “Board”) (together, the “District Defendants”), as well as against several former and current District administrators (the “Individual Defendants”). Following dismissal of several of Plaintiffs claims by Judge Colleen McMahon, to whom this case was originally assigned, Plaintiffs remaining claims are causes of action (1) against the District Defendants for gender and age discrimination and harassment, pursuant to Title VII of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. § 2000e et seq., and the Age Discrimination in Employment Act (“ADEA”), 29 U.S.C. § 621 et seq.; (2) against the District Defendants for retaliation occurring after July 28, 2005, pursuant to Title VII, the ADEA, and the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq.; and (3) against all Defendants for denial of equal protection, pursuant to 42 U.S.C. § 1983 (“Section 1983”). Defendants moved for summary judgment, and Plaintiff and Defendants also moved in limine to exclude from trial certain expert testimony on the issue of damages. For the reasons stated herein, Defendants’ motion for summary judgment is granted, and the motions to exclude testimony are denied as moot. I. Background A. Facts 1. Plaintiffs Hiring and Job Duties Plaintiff was hired by the District as a School Psychologist beginning September 1, 1993. (Defs.’ Statement of Material Facts Pursuant to Local Rule 56.1 (“Defs.’ 56.1”) ¶ 1.) At the time, she was forty-three years old. (Decl. of Peter Hoffman in Opp’n to Defs.’ Mot. for Summ. J. (“Hoffman Deck”) Ex. A (Dep. of Margaret Stofsky (“PI. Dep.”) 31).) The hiring committee considering Plaintiffs application included Frank Tolan, who served as Principal of the District’s High School throughout Plaintiffs employment with the District (Aff. of Frank Tolan in Supp. of Defs.’ Mot. for Summ. J. (“Tolan Aff.”) ¶ 1), and Karen Arnhold-Falanga, who was a School Psychologist for the District. (PI. Dep. 30.) From the beginning of Plaintiffs employment with the District through the 2003-04 school year, the District employed two School Psychologists, Plaintiff and Arnhold-Falanga. (Defs.’ 56.1 ¶¶ 36-37.) Plaintiff was responsible for the High School, Arnhold-Falanga was responsible for the Elementary School, and Plaintiff and Arnhold-Falanga were each responsible for “half of the Middle School caseload.” (Aff. of George Newman in Supp. of Defs.’ Mot. for Summ. J. (“Newman Aff.”) ¶ 3.) As of September 2001, following the construction of the new Middle School (Aff. of Cheryl Thomas in Supp. of Defs.’ Mot. for Summ. J. (“Thomas Aff.”) ¶ 15), the High School covered grades 9 through 12, and the Middle School covered grades 5 through 8. (PL Dep. 100.) The duties and responsibilities of a School Psychologist are outlined in a job description produced by the District. (Aff. of Matthew Crandell in Supp. of Defs.’ Mot. for Summ. J. (“Crandell Aff.”) ¶ 6.) As members of the District’s Special Education staff, School Psychologists report to the Director of Special Education, who may assign them unspecified “appropriate responsibilities” in addition to those specified in the job description. (Crandell Aff. Ex. O (Job Description), 1, 3.) School Psychologists are appointed to serve on Child Study Teams, the District Committee on Special Education (“CSE”), and other District-wide committees. (Id. 1.) They carry out testing, including “Psychological and Triennial evaluations,” for the CSE, “perform counseling evaluations as recommended by the Child Study Teams,” meet with parents to explain test results, and “act as ‘case manager’ [for] students referred to the CSE.” (Id. 2.) School Psychologists work with teachers and other staff “to develop behavior modification plans or consult in other appropriate areas,” work with parents “as needed to develop realistic expectations of children’s progress,” meet with parents “when issues surface in classrooms,” and “may be requested to provide inservice on clinical issues for teaching staff.” (Id.) They also counsel students, either individually or in small groups. (Id.) Finally, School Psychologists “provide[ ] the initial intervention and direction when a crisis occurs,” and “may be requested to intervene with at-risk students in special situations.” (Id. 3.) 2. Concerns With Plaintiff’s Job Performance Prior to the 2001-05 School Year According to Tolan, Plaintiff “failed to keep appropriate records pertaining to students she counseled” for “several years prior to June 2004.” (Tolan Aff. ¶ 4.) Tolan also received complaints from parents and teachers of special education students that Plaintiff was not counseling students in accordance with their Individualized Educational Plans (“IEPs”). (Id.) Some parents even asked that their children not be counseled by Plaintiff. (Id.) At some point prior to the 2004-05 school year, Tolan expressed his concerns about Plaintiff to then-Superintendent Frank DeLuca, who advised Tolan “to develop an accountability system to help [Plaintiff] improve, and to ensure that she was complying with her job requirements.” (Aff. of Frank DeLuca in Supp. of Defs.’ Mot. for Summ. J. (“De-Luca Aff.”) ¶4.) Tolan worked with Plaintiff “to develop a system for scheduling and evaluating students that would help her organize her tasks,” and held several meetings with Plaintiff and a union representative to discuss Plaintiffs schedule. (Tolan Aff. ¶ 5.) According to Tolan, Plaintiff was “reluctant to change her practices” and “questioned [Tolan] as to why [Tolan] needed counseling records from her.” (Id.) Tolan told Plaintiff that he “required all teachers to maintain lesson plans ... [and] all guidance counselors to turn in records of students they counseled, and thus, it was a matter of consistent practice that the school psychologists turn in records of students they counseled.” (Id.) George Newman, who in March 2003 became the District’s Director of Special Education and therefore Plaintiffs supervisor, considered Plaintiff to be a “very bright” and knowledgeable School Psychologist who wrote “very good” reports. (Hoffman Decl. Ex. 0 (Dep. of George Newman (“Newman Dep.”) 91).) However, Newman was concerned that Plaintiff “had been failing to submit psychological reports and student progress reports in a timely manner” and “was repeatedly missing counseling sessions with students who were assigned to her.” (Newman Aff. ¶ 4.) Newman was informed at one point that Plaintiff had missed 157 counseling sessions with students. (Id.) Tolan told Newman that Plaintiff “was not completing the required testing for special education students” and also “missed numerous counseling sessions.” (Id. ¶ 5.) Newman met with Plaintiff during the 2003-04 school year “to discuss these concerns, and to talk to her about how to manage her time more effectively.” (Id. ¶ 4.) At Plaintiffs deposition, she described a series of work-related conflicts involving herself and Tolan. According to Plaintiff, during her employment with the District, “people who had authority over [her],” including Tolan, “would talk to [her] in loud or rude and disrespectful ways.” (PI. Dep. 128.) In November 2003, Plaintiff attended a meeting at which Tolan and Newman were also present, where Tolan “accused [Plaintiff] of dumping some responsibility on him” with respect to a particular Middle School student. (Id. 152-53.) At unspecified times, Tolan “screamed” at Plaintiff, accused Plaintiff of lying, told Plaintiff that she was not worth the salary she was making and that he would like to spend it elsewhere, and walked by Plaintiffs office to check up on her. (Id. 133.) Tolan also warned Plaintiff that he would tell the “special ed directors” that Plaintiff was not doing what Tolan wanted her to do and was not counseling students in accordance with their IEPs; according to Plaintiff, Tolan did in fact tell the special ed directors these things. (Id. 134.) During unspecified staff meetings, Tolan would interrupt Plaintiff. (Id. 135.) At some point, Tolan ordered Plaintiff to find a certain student, and when Plaintiff could not locate the student, Tolan yelled at Plaintiff in presence of secretaries. (Id. 135-36.) Plaintiff stated at her deposition that she did “not think ... Tolan routinely went about screaming at any other males, [and] certainly not pretty young females.” (Id. 158.) According to Plaintiff, concerns about her work performance were also raised, prior to the 2004-05 school year, by Cheryl Thomas, who at the time was Principal of the Middle School. (PI. Dep. 138.) In the spring of 2004, Thomas sent Plaintiff a memorandum asking Plaintiff to account for her time, “implying that [she] had missed all these [counseling] sessions”; Thomas also told Plaintiff that Thomas “had been told that [Plaintiff] had a reputation for not seeing kids that [she] was supposed to.” (Id.) 3. Plaintiffs Workload-Related Complaints Prior to the 2001-05 School Year Prior to the start of the 2004-05 school year, Plaintiff requested for her “workload to be reduced.” (Pl. Dep. 93; Pl.’s Rule 56 Statement of Controverted Facts (“PL’s 56.1”) ¶ 53.) Plaintiff told Newman that she had too much work to do. (Defs.’ 56.1 ¶ 48.) Tolan and DeLuca were also aware that Plaintiff felt this way. (Tolan Aff. ¶ 5; DeLuca Aff. ¶ 7.) Plaintiff “made requests from the very beginning of [her] employment [with the District] that it would be more effective to have [her] in one place or the other,” i.e., to limit Plaintiffs responsibilities to a single school building. (Pl. Dep. 93.) Plaintiff also “made complaints to the District that [her] workload was inequitable.” (Id. 97.) Under the official division of labor between Plaintiff and Arnhold-Falanga, Plaintiff was expected to cover students in grades 7 through 12 and Arnhold-Falanga was responsible for students in grades K through 6; however, according to Plaintiff, she worked with some students in grades 5 and 6 as well as some Elementary School students. (Id. 98-99.) A Plaintiffs Assignment to the Middle School During the 2003-04 school year, Newman recommended to DeLuca that the District hire a third School Psychologist. (Newman Aff. ¶ 9.) According to Newman, he made the recommendation to DeLuca “in part due to [Plaintiffs] perception that she was being overworked.” (Id.) According to DeLuca, “Newman persuaded me that it would be beneficial for the District to have one School Psychologist in each building, as it would reduce the workload for the current School Psychologists.” (DeLuca Aff. ¶ 7.) The District subsequently decided to hire a third School Psychologist for the 2004-05 school year (Defs.’ 56.1 ¶ 59), and in the summer of 2004, a committee was established to consider candidates to fill that position (Newman Aff. ¶ 10). Both Plaintiff and Newman were members of that hiring committee. (Id.; PL Dep. 94.) The District initially offered the position to a woman who had more than twenty years of experience as a school psychologist and neuropsychologist (Defs.’ 56.1 ¶¶ 62-63), but that candidate declined the District’s offer because “the District was unable to meet her salary requirements” (Newman Aff. ¶ 11; PL’s 56.1 ¶ 64). The District ultimately hired another candidate, Matthew Crandell, who is male and at the time of his hiring was under thirty years old (Crandell Aff. ¶ 4), following the hiring committee’s recommendation (Defs.’ 56.1 ¶¶ 60-61; Newman Aff. ¶ 11). Plaintiff concurred in that recommendation, but she claims that she recommended only that Crandell be hired on the condition that Plaintiff be assigned to work at the High School. (PL’s 56.1 ¶¶ 60-61, 66; Newman Aff. ¶ 11; Pl. Dep. 94.) Notwithstanding Plaintiffs supposed request, Crandell was assigned to the High School for the 2004-05 school year. (Defs.’ 56.1 ¶ 65.) Plaintiff thus was assigned to be School Psychologist at the Middle School for the 2004-05 school year. (PL’s 56.1 ¶ 66; Pl. Dep. 95; Newman Aff. ¶ 12; Thomas Aff. ¶ 5.) According to District administrators, there were at least four reasons that Plaintiff was assigned to the Middle School rather than to the High School. First, Plaintiff had already been trained and involved in PACE, a program for children with autism that at the time was implemented at the Middle School but not at the High School, whereas Crandell had received no such training. (Tolan Aff. ¶ 8; Defs.’ 56.1 ¶¶ 55-56.) Second, District administrators believed that Thomas was “very organized,” and that Plaintiff would “benefit from Dr. Thomas’s organizational skills” (Tolan Aff. ¶ 8; Newman Aff. ¶ 13); moreover, “Dr. Thomas welcomed [Plaintiff] to come [to the Middle School] and also offered to help with [her] organization and planning” (Newman Dep. 168-69). Third, due to “the numerous complaints” that High School teachers and Guidance Counselors had made about Plaintiff, Newman “felt that reassigning [Plaintiff] to the Middle School would provide her with a fresh start that would be both beneficial to her as well as the teachers and Guidance Counselors at the High School.” (Newman Aff. ¶ 14.) Fourth, Tolan preferred that Plaintiff be assigned to work at the Middle School rather than the High School; he wanted a School Psychologist at the High School “who would do the counseling and the evaluations.” (Newman Dep. 100,169.) Plaintiff, at her deposition, stated that she was told that her assignment to the Middle School was due to “ongoing friction” between herself and Tolan. (PI. Dep. 95.) According to Plaintiff, no other reason was given to her. (Id. 96.) When asked whether Plaintiff believed that she had taken any action that caused the District to reassign her to the Middle School, Plaintiff stated that she did not. (Id. 108.) Plaintiff complained to Arnhold-Falanga, to Newman, and to union officials that she did not want to be reassigned to the Middle School. (Id. 89, 109). She told Newman and union officials that she felt she was “being moved unfairly.” (Id. 110.) Plaintiff “begged” Newman not to assign her to the Middle School, and asked him, “why doesn’t seniority count for anything!?]” (Id. 89.) According to Plaintiff, she “didn’t want to leave the building that [she] had worked in for all of the preceding years where [she] had developed relationships with the faculty, ... students, [and] guidance counselors”; moreover, she particularly enjoyed working with High School students. (Id. 92-93.) Although Plaintiff filed many union grievances against the District during her employment (id. 24), she did not file a grievance concerning her assignment to the Middle School (id. 107). 5. Plaintiffs Job Responsibilities During the 2004-05 School Year After Plaintiffs reassignment to the Middle School for the 2004-05 school year, Plaintiff continued to be responsible for at least one student outside of the Middle School. (Pl.’s 56.1 ¶ 73.) At her deposition, Plaintiff said that she had to evaluate at least one High School-age individual subsequent to the start of the 2004-05 school year but that this was only the only non-Middle School responsibility she could recall. (Pl. Dep. 112, 115.) However, Plaintiffs assignment to the Middle School did not substantially reduce her workload as compared to previous years. (Id. 99-100.) Although Plaintiff could not remember how many Middle School students she was responsible for in 2004-05, she asserted that she had just as many students as before, because students were added to her workload that had been previously handled by the guidance department rather than by a School Psychologist. (Id. 100-01.) Plaintiff stated that during the 2004-05 school year she had “counseling responsibilities,” “evaluation responsibilities,” “reevaluation responsibilities,” “crisis intervention responsibilities,” “teacher consultations,” and “administrative responsibilities,” as well as the responsibility to observe and evaluate students “out of the District,” “prep for and be the District’s witness in hearings,” “write reports,” “keep an accounting of [her] time,” attend “ten GSE meetings,” attend meetings at the behest of guidance counselors, “speak to parents,” “keep[ ] ... documentation on IEP correct,” “develop!] presentations for staff,” “teach[] teachers how to ... score achievement tests,” “present[ ] at superintendent’s conference days,” “attend[ ] ... manifestation hearings ... regarding students,” and “do all of the individual counseling and some of the group counseling for the As[p]erger Program that [she] had helped develop.” (Id. 103-05.) 6. Plaintiffs Complaints and Requests Concerning Her Middle School Office According to Thomas, when Plaintiff was assigned to the Middle School for the 2004-05 school year, Plaintiff requested that she be given a “a private room with no carpeting” as her office. (Thomas Aff. ¶ 15.) Such an office was “built specifically for” Plaintiff in or about the summer of 2004, when the District divided a “very large classroom” into a smaller classroom and two offices. (Id.) A “new HVAC system” was installed in the office space. (Id.) According to Plaintiff, she was assigned to this office despite her requests to Newman that she not be assigned there because the space “was known to have an extreme heat problem,” as it “had been a science room with solar capacity for plants, much like a greenhouse.” (PI. Dep. 120.) According to Thomas, due to the installation of the new HVAC system Thomas did not anticipate that the office would have any temperature problems. (Thomas Aff. ¶ 15.) During the 2004-05 school year, Plaintiff made several complaints about her office, including that it was sometimes too hot and sometimes too cold, that water leaked into the room when it rained, that the room was sometimes damp, that her files and equipment were not there at the start of year, and that there was not enough space. (Id.; Newman Aff. ¶ 16; PL Dep. 124-25.) Plaintiff directed these complaints to Newman, Thomas, District head of maintenance Rob Hamilton, and Assistant Superintendent Sonya Taylor. (Pl. Dep. 122-24; Newman Aff. ¶ 16.) According to Thomas, Plaintiff requested “that film be put on the windows to reduce the amount of sunlight coming through, and that the seal be fixed to keep water from leaking in.” (Thomas Aff. ¶ 15.) According to Plaintiff, she asked Taylor for the addition of wall cabinets to the office so that there would be more space, and in the alternative for a different office. (Pl. Dep. 125.) Plaintiff also requested that the air conditioning in the office be adjusted. (Id. 122.) In response to Plaintiffs complaints, Thomas “asked building and grounds to install ... heat shields ... to deflect the sunlight,” and these were installed in April 2005; Thomas also asked Plaintiff to keep a record of the temperature in her office. (Id. 119; Thomas Aff. ¶ 15.) Thomas could not herself adjust the temperature because “all adjustments to the HVAC system in the building had to be made at the High School via a computerized system.” (Thomas Aff. ¶ 15.) Plaintiff said that Hamilton likewise told her that he could not adjust the air conditioning. (Pl. Dep. 122 (“It can’t get turned on. It can’t get turned off. It can’t get adjusted. It had time frames.”).) Thomas said that she told Plaintiff “that [Plaintiff] could use an alternative room whenever she wished,” and that Thomas submitted all of Plaintiffs requests and complaints to the Facilities and Operations Department, “directing] that all repairs be made.” (Thomas Aff. ¶ 15.) When Plaintiff complained about her room to Newman, Newman advised Plaintiff to “submit a written request for maintenance,” and also informed Thomas and Hamilton of Plaintiffs complaints. (Newman Aff. ¶ 16; Newman Dep. 132.) In Plaintiffs view, the problems with the heat and air conditioning in her office were not timely addressed. (PI. Dep. 126.) Plaintiff perceived Thomas, Newman, and Hamilton as having ignored the problems with her office, because Plaintiff notified them of the problems in November 2004 and they were not fixed until April 2005. (Id. 130.) Plaintiff believed that the District was “retaliatfing]” against her by refusing to “mak[e] a reasonable office change” following her complaints about her office. (Id. 121.) At her deposition, Plaintiff said that her request for wall shelving in her office was ultimately denied, though she could not recall when. (Id. 118,130.) 7. Plaintiffs Parking-Related and Other Requests Plaintiff stated in her deposition that, sometime prior to the 2004-05 school year, she told Tolan that she had “allergies, history of asthma, [and] history of bronchitis,” and requested that she be permitted to park in a handicap parking space in front of the High School building on cold days “so that I wouldn’t have to be breathing the cold air.” (Id. 120-21.) Tolan denied her request, as well as her request for “a key to the back entrance,” which she had sought so that she would “not have to walk from the parking lot up and around because the doors are locked.” (Id. 121.) Thomas also was aware that Plaintiff had asthma (Thomas Aff. ¶ 17); according to Plaintiff, she also notified Thomas of her “history of pneumonia, history of bronchitis, fibromyalgia, ... arthritis, [and] mold allergies” (PI. Dep. 117). According to Thomas, “[o]n one occasion” Plaintiff asked for permission to park closer to the school building; in response, Thomas “allowed her to park in a lot that was reserved mainly for kitchen staff and traveling teachers.” (Thomas Aff. ¶ 17.) However, according to Plaintiff, Thomas told Plaintiff that she “could not use the parking lot close to the building” where Plaintiff wanted to park; instead, Thomas said Plaintiff “could get a doctor’s note saying [she] had a disability and use the disabled parking,” and Plaintiff did procure a handicap parking sticker, which she used to park “in the lot closer to the building with ... handicap parking.” (PI. Dep. 118-19.) According to Plaintiff, she also “notified” Thomas that she “would have to sometimes put [her] belongings on the elevator and then walk upstairs to get [her] belongings off the elevator,” and requested that Thomas install an intercom system in the hallway. (Id. 117-18.) Plaintiff said at her deposition that “things that happened” to her, including “having been denied” “a parking space closer to the building,” “felt like retaliation.” (Id. 108.) 8. Continued Concerns With Plaintiffs Job Performance During the 2004-05 school year, Thomas received complaints from parents that Plaintiff was not counseling their children in compliance with their IEPs. (Thomas Aff. ¶ 6.) Some parents also told Thomas that they “did not want their children to continue counseling with [Plaintiff] because she would fail to show up for seheduled counseling sessions.” (Id.) Special education teachers also informed Thomas that Plaintiff was not counseling their students as scheduled. (Id.) Thomas also “discovered” that Plaintiff “had indicated by initialing [certain] student reports that she had counseled [students] at certain times, but the teachers of the students could not confirm that these supposed counseling sessions took place”; Thomas consequently concluded that Plaintiff “might have been falsifying some student records.” (Id.) When “confronted” by Thomas, Plaintiff said “that she had seen the students, but only for five minutes.” (Id.) According to a December 21, 2004 memorandum from Thomas to Plaintiff, Plaintiff had on multiple occasions failed to inform administrators of appointments she had scheduled with parents on days that Plaintiff was absent from school, leading to parents coming in for appointments for which Plaintiff did not appear. (Id. Ex. M.) Crandell “often observed [Plaintiff] to be late to meetings [he] attended.” (Crandell Aff. ¶ 10.) During the 2004-05 school year, Thomas met with Plaintiff in an attempt “to assist her in becoming more successful with organizing her work obligations and meeting students’ needs.” (Thomas Aff. ¶ 7.) Thomas designed a chart for Plaintiff to use in keeping track of her obligations. (Id.) Plaintiffs schedule was set up so that Plaintiff would have the equivalent of two and one-half days per week of unstructured time in which no counseling sessions were scheduled. (Id.) Plaintiff also was provided with secretarial support; she was, to Thomas’s knowledge, the only School Psychologist who received such support. (Id. ¶ 9.) Thomas and Newman discussed Plaintiffs perceived “failure to counsel students in compliance with their IEPs,” and they subsequently met jointly with Plaintiff to discuss her performance. (Id. ¶ 8.) At the meeting, Plaintiff disputed Thomas and Newman’s “assessment ... that she was underperforming,” but the three “agreed on a schedule” for Plaintiff to “complete] her scheduled counseling sessions.” (Id.) In Thomas’s view, however, Plaintiffs “practices did not sufficiently change.” (Id. ¶ 9.) According to Plaintiff, in the spring of 2005, she received a memorandum, signed by Newman, which stated that Thomas alleged that Plaintiff had missed 157 counseling sessions. (PI. Dep. 67.) Newman signed that memorandum without having told Plaintiff that he had done so. (Id. 151.) Plaintiff repeatedly asked Newman to meet with her so that she could explain those “so[-]called misses” to Newman; however, Newman did not meet with Plaintiff. (Id. 151-52.) At some point, possibly around the beginning of the 2004-05 school year, Plaintiff was asked to attend a meeting with Arnhold-Falanga and Crandell, at which two attorneys were present, and Plaintiff was “grillfed] ... as to why [she] believed [that a certain] child ... ha[d] a disability.” (Id. 133.) In memoranda from Thomas to Plaintiff, dated January 7, 2005, and December 2, 2005, Thomas indicated that parents of children previously counseled by Plaintiff had requested that Plaintiff no longer counsel their children. (Thomas Aff. Ex. K, at first and fourth unnumbered pages.) A letter to Thomas from a third set of parents, dated January 3, 2006, made the same request, as did a letter to Plaintiff from a fourth set of parents, dated January 4, 2006. (Id. at second, third, and fifth unnumbered pages.) The December 2, 2005 memorandum from Thomas to Plaintiff indicated that responsibility for counseling the student had been transferred to another District employee in accordance with the parent’s stated preferences. (Id. at first unnumbered page.) The memorandum also stated that, to date, this was the fourth instance of a parent requesting a different counselor for their child due to complaints about Plaintiff. (Id.) 9. Issuance of Plaintiffs Professional Improvement Plan In 2005, Thomas and Newman “decided to develop and issue [Plaintiff] a Professional Improvement Plan (‘PIP’).” (Thomas Aff. ¶ 11.) Thomas presented the PIP to Plaintiff and her union representative at a meeting on November 1, 2005. (Id.) Thomas, Newman, Plaintiff, and Plaintiffs union representative also met on November 9, 2005, at which time Plaintiff “expressed disagreement with the PIP, but signed it.” (Id. ¶ 12; Newman Aff. ¶ 17.) The PIP stated that Plaintiffs goals would be to “improve organizational and interpersonal skills” and to “meet professional and legal obligations.” (Thomas Aff. Ex. N (PIP).) The PIP listed eighteen steps that Plaintiff would take and the time period in which Plaintiff would take those steps; for instance, the PIP stated that Plaintiff would “[organize office files and supplies” in November 2005, “[s]end reports to the Special Education Department as completed” throughout the 2005-06 school year, and “[b]e in [her] office when students are scheduled to arrive” on an ongoing basis. (Id.) At the bottom of the PIP, before signing her name, Plaintiff wrote: “I have been forced by administration [sic] to sign this document. I disagree with the content and the manner in which I was forced to sign. My union representative has advised me to sign this so that I won’t be insubordinate. This is the only reason I have initialed and signed.” (Id.) Plaintiff stated at her deposition that she did not think that administrators would have “forc[ed] a male [employee] to sign a document” such as Plaintiffs PIP. (PI. Dep. 159.) According to Thomas, Plaintiff subsequently complied with “some aspects” of the PIP, by giving Thomas “logs of her counseling sessions” and keeping records of the “time she had spent in session with students.” (Thomas Aff. ¶ 13.) On November 16, 2005, Plaintiff filed a grievance regarding her PIP. (Hoffman Deck Ex. D (Dep. of Frank DeLuca (“De-Luca Dep.”) 51); Newman Dep. 126-27.) Plaintiff asked that the District “[e]xpunge” Plaintiffs PIP, grant Plaintiff “release time to complete IEP[s],” and “[c]ease and desist from harassment and overly broad requirements” and “inequitable treatment” of Plaintiff. (DeLuca Dep. 54.) According to DeLuca, the fact that a grievance used the word “harassment” would not necessarily cause the District to investigate whether unlawful harassment took place, because the District had a formal process for making a complaint of discriminatory harassment. (Id. 57.) At his deposition, DeLuca could not recall whether Plaintiff was given the proper form for making such a complaint following her grievance. (Id. 58.) Plaintiff asserted at her deposition that administrators “were not asking the younger male psychologist [Crandell] to have that same kind of documentation that [Plaintiff] was forced to do.” (PI. Dep. 159.) According to Crandell, however, Tolan “has on a number of occasions requested that I provide him my weekly counseling calendar to verify that I have counseled the students who are required to receive counseling.” (Crandell Aff. ¶ 8.) Plaintiff, her union representative, De-Luca, and Newman met to discuss Plaintiffs grievance. (Newman Dep. 127.) At the meeting, Newman said that they “could take a look at the [PIP],” which Plaintiff “felt ... was too broad,” and that they “could work together to taper it down,” bub — -although at his deposition Newman could not recall what he had actually said — he “would probably have said that we were not going to expunge” the PIP. (Id. 128-29.) 10. Plaintiffs Allegations of Unfair Treatment by Thomas and Newman At Plaintiffs deposition, she made various accusations of what she perceived as unfair treatment by Thomas and Newman. According to Plaintiff, Thomas sometimes “ma[d]e ... decisions]” about matters concerning Plaintiff and “ma[d]e accusations toward” Plaintiff based solely on information from other sources, such as parents, “without any verification whatsoever.” (PL Dep. 139.) For example, following an incident that transpired in an unspecified year, a child’s parent asked that Plaintiff never speak with the child again, and Thomas directed Plaintiff not to contact the child, and declined to hear Plaintiffs side of the story. (Id. 139-41.) In 2004 or 2005, Thomas discontinued a child’s counseling with Plaintiff without first discussing the situation with Plaintiff. (Id. 141-42.) Also in 2004 or 2005, Thomas made a decision about another child over Plaintiffs objections. (Id. 142-44.) At some unspecified time, Thomas directed an individual named Helen Levóte to “spy” on Plaintiff. (Id. at 144^15.) Levóte was put in charge of Plaintiffs schedule and was instructed to write Plaintiffs passes rather than allow Plaintiff to write them herself. (Id. 145.) At some point between September 2004 and December 2005, Plaintiff asked Thomas to stop having Levóte make Plaintiffs passes; Thomas told Plaintiff, “you have the reputation that you don’t see your kids,” and Thomas was “just making sure that you do.” (Id. 145-46.) Sometime in 2004 or 2005, Newman told Plaintiff, during a phone conversation, that Plaintiff was “being a pain in the ass.” (Id. 129, 131.) Plaintiff complained to Arnhold-Falanga, who was a union representative, about Newman’s comment. (Id. 131.) At some unspecified time, Thomas decided not to allow Plaintiff to miss any counseling sessions, which was “completely different” than the policy imposed on the District’s other School Psychologists. (Id. 146.) In or around January 2005, Plaintiff said something to a student’s parent that led to the parent becoming very upset and calling the student’s teacher. (Id. 156-57.) The teacher blamed the situation on Plaintiff, and at a meeting held to discuss the situation, Newman supported the teacher’s position. (Id. 157.) During the spring of 2005, Thomas either called or directed someone to call Plaintiff “over the loudspeaker at the same time [Thomas] was calling the kids into detention,” which Plaintiff viewed as “obnoxious harassment.” (Id. 149.) Plaintiff testified that she did not think administrators would have called a male employee on the loudspeaker. (Id. 159.) At a meeting attended by Plaintiff, Newman, Thomas, and a union representative, possibly in the spring of 2005, Newman wrongly accused Plaintiff of not completing certain evaluations. (Id. 154.) At some unspecified time, following an incident in which Plaintiff angered a student’s parent by calling the parent and telling her to come in to the school, Plaintiff attended a meeting with the parent, Thomas, and Newman. (Id. 154-55.) At the meeting, the parent aggressively questioned Plaintiff and took out a tape recorder to record the conversation; Newman asked the parent to stop recording the meeting, “but allowed her to continue to question [Plaintiff] in this nasty awful tone of voice.” (Id. 155.) According to Plaintiff, at the start of the 2005-06 school year, Newman told Plaintiff he was angry at her for not being available to attend a CSE meeting of which Plaintiff claims she was not made aware. (Id. 131.) Plaintiff believed that Newman expressed that anger to Plaintiff in retaliation for Plaintiffs unavailability to work during the previous summer. (Id.) Plaintiff called Arnhold-Falanga to tell her about this incident, but she did not ask the union to file a grievance on her behalf, and she could not recall at her deposition if she asked the union to take any action due to this incident. (Id. 132.) 11. Plaintiff’s Final Days of Active Employment with the District On December 21, 2005, Plaintiff attended a meeting with Newman, special education teacher Rebecca Wilt, guidance counselor Gail Dow-Goldberg, the parent of a District special education student, and the parent’s companion; Plaintiff arrived at the meeting late. (Pl.’s 56.1 ¶¶ 105-09; Newman Aff. ¶ 18; Aff. of Rebecca Wilt in Supp. of Defs.’ Mot. for Summ. J. (“Wilt Aff.”) ¶¶ 2-3; Aff. of Gail Dow-Goldberg in Supp. of Defs.’ Mot. for Summ. J. (“Dow-Goldberg Aff.”) ¶ 3.) Plaintiff sat approximately five feet from Newman. (Wilt Aff. ¶ 3.) According to Plaintiff and Newman, during the meeting, while Plaintiff was talking to the parent, Newman touched Plaintiffs arm to interrupt her. (PL’s 56.1 ¶¶ 105-09; Newman Aff. ¶ 18.) Plaintiff alleged that Newman “grabbed [her] arm” for probably between five and ten seconds “in an attempt to stop [her] from speaking,” but that she “continued the conversation for some time period while he was still grabbing my arm.” (Pl. Dep. 160-61,163.) According to Newman, he merely happened to “touch[ ]” Plaintiffs arm “[i]n the course” of “gesturing] to [her] that [he] had something to say ... to the parent at that moment,” and upon doing so he “was able to get a word in edgewise”; no one at the meeting reacted to Newman touching Plaintiffs arm, including Plaintiff. (Newman Aff. ¶ 18.) In fact, neither Wilt nor Dow-Goldberg noticed that Newman had touched Plaintiffs arm during the meeting (Wilt Aff. ¶ 5; Dow-Goldberg Aff. ¶ 4), although Plaintiff asserted at her deposition that she later “said something” to Dow-Goldberg in reference to the incident “about what the hell was that,” and that Dow-Goldberg responded by saying “yeah, what was that[?]” (PL Dep. 167-68). Plaintiff suffered no physical injury as a result of the incident. (Defs.’ 56.1 ¶ 110.) Plaintiff stated at her deposition that she did not think Newman “would have ever grabbed a male [individual’s] arm” during a meeting with a parent. (Pl. Dep. 158.) On December 22, 2005, Plaintiff attended a meeting with Newman, DeLuca, and two union representatives. (DeLuca Aff. ¶ 8; Newman Aff. ¶ 19.) According to Newman, he “requested the meeting to discuss the fact that [Plaintiff] had attempted to change a student’s [IEP] without following the proper procedures through the CSE.” (Newman Aff. ¶ 19.) According to DeLuca, at the meeting it was mentioned that Plaintiff had attempted to make such a change, and also had missed over 157 counseling sessions. (De-Luca Aff. ¶ 8.) According to Newman and DeLuca, Plaintiff disputed Newman’s allegations at the meeting and appeared to be angry. (Id.; Newman Aff. ¶ 19.) According to Plaintiff, DeLuca “said something [to Plaintiff] to the effect of [’]you’re not in private practice^] in a funny tone of voice”; this comment made Plaintiff “very upset.” (Pl. Dep. 137-38.) At the meeting, neither Plaintiff nor her union representatives mentioned Newman’s touching of Plaintiffs arm the previous day. (PL’s 56.1 ¶¶ 117-18.) 12. Cessation of Plaintiffs Employment at the District Plaintiff did not return to active employment at the District after December 22, 2005.(Defs.’ 56.1 ¶ 2.) From December 23, 2005 through January 3, 2006, Plaintiff was on vacation during the District’s winter recess. (Id. ¶3.) As of January 4, 2006, Plaintiff requested and received indefinite sick leave, and she took sick leave through June 23, 2006, i.e., through the end of the school year. (Id. ¶¶ 5-6.) Plaintiff received full benefits and pay from the District for the remainder of the 2005-06 school year. (Id. ¶ 6.) Plaintiff requested to take educational leave for the 2006-07 school year, and her request was granted by the Board on August 28, 2006. (Id. ¶ 8.) The District hired a temporary School Psychologist, Matthew Whitehurst, to replace Plaintiff at the Middle School for the 2006-07 school year. (Id. ¶ 19; Whitehurst Aff. ¶¶ 5, 7.) Whitehurst is male and was under thirty years old at the time of his hiring. (Whitehurst Aff. ¶ 3.) Plaintiff was advised that she was to notify the District by no later than March 1, 2007 of whether she intended to return to her position at the District for the 2007-08 school year. (Defs.’ 56.1 ¶ 20.) Plaintiff failed to do so (id. ¶ 21), and according to Joseph Sciortino, who had replaced DeLuca as District Superintendent in 2006, Plaintiff finally notified the District in August 2007 that she did not plan to return to work. (Aff. of Joseph Sciortino in Supp. of Defs.’ Mot. for Summ. J. ¶¶ 1, 5.) On August 20, 2007, the Board unanimously passed a resolution deeming Plaintiff “to have voluntarily resigned from the position of School Psychologist effective July 20, 2007,” and Sciortino sent Plaintiff a letter, dated August 22, 2007, that informed her of the resolution. (Id. Ex. J.) B. Procedural History On May 30, 2006, while Plaintiff was on paid sick leave from the District, Plaintiff filed a complaint of discrimination with the Equal Employment Opportunity Commission (“EEOC”). (Defs.’ 56.1 ¶ 23.) Plaintiff, represented by current counsel, alleged in her EEOC complaint that the District discriminated against her on the basis of age, gender, and disability; that the District subjected her to a hostile work environment that “forced [her] to take a medical sick leave”; and that she was the victim of unspecified retaliation. (Aff. of Jacinda Conboy in Supp. of Defs.’ Mot. for Summ. J., Ex. Q (EEOC Compl.) ¶ 3.) On July 24, 2006, the EEOC dismissed Plaintiffs complaint for failure to state a claim and notified Plaintiff of her right to bring suit. (Defs.’ 56.1 ¶ 24.) On October 23, 2006, Plaintiff and her husband, Eric Stofsky, commenced this action by filing a Complaint against the Board, the District, Tolan, Newman, Thomas, DeLuca, Sciortino, unnamed District administrators, and Pauline Kaplan, who was president of the Board. Plaintiff and Eric Stofsky filed an Amended Complaint on February 22, 2007. Defendants moved to dismiss. Judge McMahon referred the motion to Magistrate Judge Mark D. Fox, who issued a Report and Recommendation (“R & R”) on June 20, 2007. In his R & R, Magistrate Judge Fox recommended that Defendants’ motion to dismiss be granted in part and denied in part. Judge McMahon, in an order filed August 2, 2007, dismissed (1) all claims against Sciortino and Kaplan, (2) all Title VII, ADEA, and ADA claims against the remaining Individual Defendants, (3) all Title VII, ADEA, and ADA retaliation claims relating to acts committed prior to July 28, 2005, as time-barred, (4) Plaintiffs non-retaliation claim of discrimination under the ADA, as time-barred, (5) Plaintiffs claim under the Rehabilitation Act, (6) all claims of due process violations under Section 1983, and (7) all state law claims, including Eric Stofsky’s claim for loss of consortium, which was his sole claim. The remaining claims, all asserted solely by Plaintiff, are that Plaintiff suffered (1) gender and age discrimination and harassment by the District Defendants, in violation of Title VII and the ADEA, (2) retaliation by the District Defendants after July 28, 2005, in violation of Title VII, the ADEA, and the ADA, and (3) denial of equal protection by all Defendants, in violation of Section 1983. Defendant moved for summary judgment on August 1, 2008. Plaintiff moved on August 29, 2008, to disqualify Defendants’ expert witness, and Defendant moved on September 2, 2008, to disqualify Plaintiffs expert witness. Oral argument was held on March 18, 2009. II. Discussion A. Standard of Review Summary judgment may be granted when it is shown that there is “no genuine issue as to any material fact and that the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(c); see also Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). “When ruling on a summary judgment motion, the district court must construe the facts in the light most favorable to the non-moving party and must resolve all ambiguities and draw all reasonable inferences against the movant.” Dallas Aerospace, Inc. v. CIS Air Corp., 352 F.3d 775, 780 (2d Cir.2003). A party seeking summary judgment bears the burden of establishing that no genuine issue of material fact exists. See Atl. Mut. Ins. Co. v. CSX Lines, L.L.C., 432 F.3d 428, 433 (2d Cir.2005). “When the burden of proof at trial would fall on the nonmoving party, it ordinarily is sufficient for the movant to point to a lack of evidence to go to the trier of fact on an essential element of the nonmovant’s claim. In that event, the nonmoving party must come forward with admissible evidence sufficient to raise a genuine issue of fact for trial in order to avoid summary judgment.” Jaramillo v. Weyerhaeuser Co., 536 F.3d 140, 145 (2d Cir.2008) (internal citations omitted). “When the moving party has carried its burden under Rule 56(c), its opponent must do more than simply show that there is some metaphysical doubt as to the material facts.” Matsushita Elec. Indus. Co., Ltd. v. Zenith Radio Corp., 475 U.S. 574, 586, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986) (footnote omitted); see also McPherson v. N.Y. City Dep’t of Educ., 457 F.3d 211, 215 n. 4 (2d Cir.2006) (“[S]peculation alone is insufficient to defeat a motion for summary judgment.”). The Second Circuit has “repeatedly expressed the need for caution about granting summary judgment to an employer in a discrimination case where ... the merits turn on a dispute as to the employer’s intent.” Holcomb v. Iona Coll., 521 F.3d 130, 137 (2d Cir.2008). “Where an employer has acted with discriminatory intent, direct evidence of that intent will only rarely be available, so that ‘affidavits and depositions must be carefully scrutinized for circumstantial proof which, if believed, would show discrimination.’ ” Id. (quoting Gallo v. Prudential Residential Servs., 22 F.3d 1219, 1224 (2d Cir.1994)). “Even in the discrimination context, however, a plaintiff must provide more than conclusory allegations to resist a motion for summary judgment.” Id.; see also Abdu-Brisson v. Delta Air Lines, Inc., 239 F.3d 456, 466 (2d Cir.2001) (“It is now beyond cavil that summary judgment may be appropriate even in the fact-intensive context of discrimination cases.... [TJrial courts should not treat discrimination differently from other ultimate questions of fact.” (internal quotation marks omitted)). B. Hostile Work Environment Claims Plaintiff claims that the District Defendants discriminated against her on the basis of her gender, in violation of Title VII, and on the basis of her age, in violation of the ADEA, by subjecting her to a hostile work environment. “To state a claim for a hostile work environment in violation of Title VII, a plaintiff must plead facts that would tend to show that the complained of conduct: (1) is objectively severe or pervasive'—that is, ... creates an environment that a reasonable person would find hostile or abusive; (2) creates an environment that the plaintiff subjectively perceives as hostile or abusive; and (3) creates such an environment because of the plaintiffs sex.” Patane v. Clark, 508 F.3d 106, 113 (2d Cir.2007) (internal quotation marks omitted). The analogous standards apply to a claim of hostile work environment under the ADEA, see Terry v. Ashcroft, 336 F.3d 128, 147-48 (2d Cir.2003); the plaintiff must establish that she was subjected to a hostile work environment because of her age, see Kassner v. 2nd Ave. Delicatessen Inc., 496 F.3d 229, 240-41 (2d Cir.2007). Defendants do not appear to contest that Plaintiff subjectively viewed the District Defendants’ conduct as hostile or abusive, but they assert that Plaintiff fails to satisfy the other two requirements for a triable case. 1. Objective Abusiveness “Conduct that is not severe or pervasive enough to create an objectively hostile or abusive work environment—an environment that a reasonable person would find hostile or abusive—is beyond Title VII’s purview.” Harris v. Forklift Sys., Inc., 510 U.S. 17, 21, 114 S.Ct. 367, 126 L.Ed.2d 295 (1993). “[Wjhether an environment is ‘hostile’ or ‘abusive’ can be determined only by looking at all the circumstances. These may include the frequency of the discriminatory conduct; its severity; whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it unreasonably interferes with an employee’s work performance.” Id. at 23, 114 S.Ct. 367. “[A] single event, if extraordinarily severe, could alter the conditions of a working environment” and provide grounds for finding a hostile work environment. Mathirampuzha v. Potter, 548 F.3d 70, 79 (2d Cir.2008) (internal quotation marks omitted). “[F]or example, a rape, or an obscene and humiliating verbal tirade that undermines the victim’s authority in the workplace,” could be sufficiently “severe as to alter materially [an employee’s] working conditions.” Id. (internal citation omitted); see also Alfano v. Costello, 294 F.3d 365, 373-74, 379-80 (2d Cir.2002) (stating the applicable standard for a hostile work environment and collecting cases). Construing the facts in the light most favorable to Plaintiff, and resolving all ambiguities and drawing all reasonable inferences in favor of Plaintiff, the Court is willing to assume that Plaintiff has established a genuine issue of material fact as to whether the District Defendants subjected her to a work environment that a reasonable person would find hostile or abusive. According to Plaintiffs deposition testimony, District administrators repeatedly burdened Plaintiff with an unreasonable amount of work and not enough time to do it, unfairly yelled at her with co-workers present, unfairly accused her of lying, spread lies about her, told her that she was unwanted and a “pain in the ass,” resolved work-related disputes against her without first hearing her side of the story, assigned her to work for many months in an office where temperatures sometimes exceeded 100 degrees, and on one occasion grabbed her arm during a meeting and restrained her for up to ten seconds. Cf. Howley v. Town of Stratford, 217 F.3d 141, 154 (2d Cir.2000) (holding that a coworker’s “conduct could reasonably be viewed as having intolerably altered [the plaintiffs] work environment,” because although the coworker “made his obscene comments only on one occasion, the evidence is that he did so at length, loudly, and in a large group in which [the plaintiff] was the only female and many of the men were her subordinates”). Assuming arguendo that all of these alleged events may be considered notwithstanding the applicable statutes of limitations, the Court further assumes that a reasonable jury could find such conduct to be sufficiently severe as to create a hostile work environment. 2. Abusiveness Due to Gender or Age However, Plaintiffs hostile work environment claims fail because she has not produced any evidence from which a jury could conclude that she was subjected to an abusive work environment on the basis of her gender or age. For example, Plaintiff has introduced no evidence of any gender-related or age-related comments made or actions taken by any District administrator or co-worker, with the exception of Plaintiffs recollection that on a “[e]ouple” of unspecified occasions, unspecified individuals “jointly mentioned” that Plaintiff was the oldest person in the room (PI. Dep. 88); however, Plaintiff took no offense at these statements and does not suggest that they are evidence of discriminatory animus by the District Defendants, although even if she did, evidence of the statements would not be sufficient to survive summary judgment. See Douglas v. Dist. Council 37 Mun. Employees’ Educ. Fund Trust, 207 F.Supp.2d 282, 291 (S.D.N.Y.2002) (“ ‘Stray’ comments do not raise an inference of discrimination.”). Beyond these stray comments, Plaintiffs counsel was unable, when asked at oral argument, to identify a single example of harassing conduct that could be linked to gender or age bias. In lieu of evidence, Plaintiff offers mere speculation that her mistreatment was related to her gender or age. At her deposition, Plaintiff said that she did “not think” that Tolan “routinely went about screaming” either at men or at younger women. Plaintiff expressed her view that Newman likely would not have grabbed the arm of a male colleague in the way he allegedly grabbed Plaintiffs arm, that District administrators would not have asked a male School Psychologist to sign an inappropriate or unfair PIP, and that Thomas would not have paged a male colleague over the school loudspeaker system. Plaintiff further asserted — without specifying the basis for her personal knowledge — that Crandell, who is male and younger than Plaintiff, was not asked to do the same kind of documentation required of Plaintiff. Such obviously self-serving and wholly unsubstantiated conjecture does not justify advancing this ease to the trial stage. See McPherson, 457 F.3d at 215 n. 4 (“[Speculation alone is insufficient to defeat a motion for summary judgment.”). Simply put, there is no admissible evidence from which a jury could reasonably infer that Plaintiff was mistreated on account of her gender or age. In fact, the available evidence is to the contrary. According to Crandell, Tolan was a demanding supervisor of younger men as well as of older women; during Crandell’s employment with the District, Tolan raised his voice at Crandell and placed blame on him. Crandell and Whitehurst, both male School Psychologists younger than Plaintiff, stated that their jobs were quite challenging and that their supervisors required them to produce documentation of their counseling schedules. Moreover, even if Plaintiff has demonstrated that she was treated differently from other School Psychologists who were younger or male, which she has not, she has failed to offer any evidence — other than her own subjective views that she was doing a good job as a School Psychologist for the District, that she was always right and her supervisors wrong in disputes about how to counsel students or deal with their parents, that she was justified in missing her scheduled counseling sessions, and so on — that would support an inference that Plaintiffs supervisors were unjustified in the way they treated her, let alone an inference that they subjected her to a hostile work environment because of her gender or her age. See Alfano, 294 F.3d at 378 (“Facially neutral incidents may be included, of course, among the ‘totality of the circumstances’ that courts consider in any hostile work environment claim, so long as a reasonable fact-finder could conclude that they were, in fact, based on sex. But this requires some circumstantial or other basis for inferring that incidents sex-neutral on their face were in fact discriminatory.”). At most, all Plaintiff has established is that District administrators were not the most nurturing supervisors. But the law does not require civility, see Oncale v. Sundowner Offshore Serus., Inc., 523 U.S. 75, 80, 118 S.Ct. 998, 140 L.Ed.2d 201 (1998) (noting that Title VII is not “a general civility code for the American workplace”); it only requires that employers not manifest discriminatory animus in their supervision of employees. 3. Faragher/Ellerth Defense In the alternative, assuming arguendo that Plaintiff has established sufficient evidence from which a jury could conclude that Plaintiff was subjected to a hostile work environment because of her age or gender, the District Defendants would still be entitled to summary judgment on grounds that Plaintiff unreasonably failed to make any complaints about gender or age harassment. “When no tangible employment action is taken, a defending employer may raise an affirmative defense ... :(a) that the employer exercised reasonable care to prevent and correct promptly any sexually harassing behavior, and (b) that the plaintiff employee unreasonably failed to take advantage of any preventive or corrective opportunities provided by the employer or to avoid harm otherwise.” Faragher v. City of Boca Raton, 524 U.S. 775, 807, 118 S.Ct. 2275, 141 L.Ed.2d 662 (1998); Burlington Indus., Inc. v. Ellerth, 524 U.S. 742, 765, 118 S.Ct. 2257, 141 L.Ed.2d 683 (1998). “No affirmative defense is available, however, when the supervisor’s harassment culminates in a tangible employment action, such as discharge, demotion, or undesirable reassignment.” Faragher, 524 U.S. at 808, 118 S.Ct. 2275; Ellerth, 524 U.S. at 765, 118 S.Ct. 2257. The Faragher/Ellerth defense also applies to claims of hostile work environment in violation of the ADEA. See Knutson v. Brounstein, No. 99-CV-6094, 2001 WL 1661929, at *5 (S.D.N.Y. Dec. 27, 2001) (applying Faragher/Ellerth defense to ADEA claim); Irvine v. Video Monitoring Servs. of Am., L.P., No. 98-CV-8725, 2000 WL 502863, at *5 (S.D.N.Y. Apr. 27, 2000) (same); cf. Terry, 336 F.3d at 148 (noting that the “same standards apply to hostile work environment claims brought under the ADEA” as apply to claims brought under Title VII). Plaintiff claims that Defendants cannot raise the Faragher/Ellerth defense in light of Plaintiffs claims that her harassment “culminate[d] in a tangible employment action,” namely “reassign[ment] against her wishes” and then “constructive[] discharge[ ].” (PL’s Mem. in Opp’n to Defs.’ Mot. for Summ. J. (“PL’s Mem.”) 9.) This argument is unavailing. First, because Plaintiffs claim of constructive discharge is based on the same evidence as her hostile work environment claim, and not that she “quit[ ] in reasonable response to an employer-sanctioned adverse action officially changing her employment status or situation,” Pa. State Police v. Suders, 542 U.S. 129, 134, 124 S.Ct. 2342, 159 L.Ed.2d 204 (2004) (emphasis added), the alleged constructive discharge does not “rank[ ] as a tangible employment action” for purposes of negating a Faragher/Ellerth defense, id. at 140, 124 S.Ct. 2342; see also Pugni v. Reader’s Digest Ass’n, No. 05-CV-8026, 2007 WL 1087183, at *17 (S.D.N.Y. Apr. 9, 2007) (“[A] constructive discharge, even if established by the plaintiff, does not amount to a tangible employment action in the context of a Faragher/Ellerth defense.” (citing Caridad v. Metro-North Commuter R.R., 191 F.3d 283, 294-95 (2d Cir.1999), overruled on other grounds by In re Initial Pub. Offerings Sec. Litig., 471 F.3d 24 (2d Cir. 2006))). Second, Defendants can raise the defense to defeat Plaintiffs hostile work environment claim only if Plaintiffs alleged “tangible employment action” — undesirable reassignment — -“was not part of the supervisor’s discriminatory harassment.” Id. Though Plaintiff may have perceived her reassignment to the Middle School as undesirable, Plaintiff has completely failed to rebut the evidence that she was reassigned for reasons unrelated to any alleged harassment, namely, because the District decided (at Plaintiffs own suggestion) to employ one School Psychologist at each of the District’s schools, because it was felt that Plaintiff would benefit from working at the Middle School with Thomas, because Plaintiff had been trained in a program for autistic children that was only instituted at the Middle School, and because many High School staff members, including Tolan, had complained about Plaintiffs work. Thus, the Court considers whether Plaintiff has raised any genuine issue of material fact as to the District Defendants’ asserted Faragher/Ellerth defense. Plaintiff does not dispute that the District Defendants satisfy the first prong of the defense, but denies that Plaintiffs failure to make a harassment complaint was unreasonable. (Pl.’s Mem. 9.) Instead, Plaintiff contends that it was reasonable for her to avoid making a complaint, for three reasons. First, she was supposed to report her complaints of harassment to Tolan and Thomas, who she claims had themselves taken part in the harassment. (Id.) Second, she believed that reporting the harassment would require “face-to-face confrontation” with her alleged harassers, “which she felt unable to participate in due to the prolonged harassment.” (Id.) Third, her doctors directed her “to not have further contact with the District after her departure,” so she was unable to file a complaint after December 22, 2005. (Id. 9-10.) These arguments are unavailing. “Once an employer has satisfied its initial burden of demonstrating that an employee has completely failed to avail herself of the complaint procedure, the burden of production shifts to the employee to come forward with one or more reasons why the employee did not make use of the procedures. The employer may rely upon the absence or inadequacy of such a justification in carrying its ultimate burden of persuasion.” Leopold v. Baccarat, Inc., 239 F.3d 243, 246 (2d Cir.2001). For an employee’s “reluctance [to report harassment] to preclude the employer’s affirmative defense, it must be based on apprehension of what the employer might do” in response to the employee’s complaint. Id. (internal quotation marks omitted) (alteration in Leopold). “Evidence must be produced to the effect that the employer has ignored or resisted similar complaints or has taken adverse actions against employees in response to such complaints.” Id. Because Plaintiff “did not come forward with any such evidence,” id., in support of her view that her failure to complain was reasonable, she cannot defeat Defendants’ Faragher/EUerth defense. See Caridad, 191 F.3d at 295 (holding