This sample memorandum of law in support of defendants’ motion for summary judgment addresses an employee's retaliation, hostile work environment, and discrimination claims based on her age, national origin, and sex, in violation of Title VII, Section 1981, the New York State Human Rights Law (NYSHRL), and the New York City Human Rights Law (NYCHRL). Among other things, the brief discusses individual liability under the NYSHRL and NYCHRL. The district court granted summary judgment in Petrisch v. HSBC Bank USA, Inc., 2013 U.S. Dist. LEXIS 45346 (E.D.N.Y. Mar. 28, 2013).