that was specifically motivated by these particular complaints. 16 . Plaintiff testified that he had an unpleasant verbal exchange with Nawoichyk at a home improvement store in January 2009, but this does not represent an adverse action sufficient to sustain a claim of First Amendment retaliation. Cf. Scott v. City of New York Dep't of Correction, 641 F.Supp.2d 211, 231 (S.D.N.Y.2009) (“[V]erbal abuse is typically insufficient to constitute an 'adverse employment action' because negative or otherwise insulting statements are hardly even actions, let alone 'adverse actions.’ ”) (internal quotation marks omitted), aff'd sub nom. Scott v. N.Y.C. Dep’t of Correction, 445 Fed.Appx. 389 (2d Cir.2011); Bartley v. Collins, No. 95 Civ. 10161(RJH), 2006 WL 1289256, at *6 (S.D.N.Y. May 10, 2006) (<HOLDING>). 17 . Additionally, Plaintiff does not even
holding do you think i need a lawyer to be ambiguous holding that verbal threats such as we going to get you you better drop the suit do not rise to the level of adverse action holding that the district courts question do you also understand that under some circumstances you or the government may have the right to appeal any sentence that i impose did not comply with rule llbln and failed to properly notify the defendant about the waiver of his appellate rights holding that if you do not qualify under the hup test you never get to the statute holding that verbal threats if they are specific can constitute adverse action for retaliation purposes