Moreover, he has not alleged that defendants engaged in wrongful conduct directed at the prospective third parties (seeDevash, 104 A.D.3d at 79, 959 N.Y.S.2d 10 ). His defamation claim also fails because the complaint does not plead with any particularity what false statements defendants had made about him and to whom (seeFlowers v. Stillrock Mgt., Inc., 179 A.D.2d 361, 362, 578 N.Y.S.2d 546 [1st Dept. 1992] ). In any event, to the extent defendants’ statements are based on the Equal Employment Opportunity Commission complaint filed by the employee who complained of plaintiff's behavior, the statements are protected under Civil Rights Law § 74 (see e.g.Lacher v. Engel, 33 A.D.3d 10, 817 N.Y.S.2d 37 [1st Dept. 2006] ; see alsoBernstein v. Seeman, 593 F.Supp.2d 630, 636 [S.D. N.Y.2009] )

Plaintiff Newman also argues a defamation theory arising from Ferdenzi's alleged statement to other Bureau employees at the August 28, 1999 meeting, announcing that Newman had been "fired" (a true statement), intimating that it was for cause (again, true), and implying that Newman was untrustworthy and underhanded. The particular words giving rise to the implication are not set forth in any manner that would support a defamation claim, leaving only a vague and conclusory allegation requiring the dismissal of claims arising from these alleged statements (Vardi, supra;Flowers v. Stillrock Management, 179 A.D.2d 361; Alanthus Corp. v. Travelers Insurance Co., 92 A.D.2d 830). The challenge to the Koretz letter suffers from the same defect, that the particular defamatory words are not alleged in the complaint.

The only First Department case dealing with the pre-answer motion to dismiss in this context found by this court is Flowers v. Stillrock Management Inc., 179 A.D.2d 361, 578 N.Y.S.2d 546 [1st Dept. 1992], which held that a former employee did not plead any facts from which it could be concluded that she was subjected to sex discrimination, by being terminated due to her pregnancy. “The standards for establishing unlawful discrimination under section 296 of NYSHRL are the same as those governing Title VII cases under the Federal Civil Rights Act of 1964” ( Mittl, citing Ferrante v. American Lung Assn., 90 N.Y.2d 623, 629, 665 N.Y.S.2d 25, 687 N.E.2d 1308 [1997];see generally, Espaillat v. Breli Originals, 227 A.D.2d 266, 268, 642 N.Y.S.2d 875 [1st Dept. 1996];42 USC § 2000e et seq.; see42 USC § 2000e–2[a][1] ).