speech had the potential to interfere with the operations of government. Jeffries v. Harleston, 52 F.3d 9, 13 (2d Cir.1995). Even by defendants own admission, in their lengthy analysis of the question of third-party standing, this case has nothing to do with the speech of plaintiff. See Defendants’ Memorandum of Law at 10-13. The Court thus dismisses defendants argument that plaintiffs speech had the potential to interfere with his job functions since, by defendants own admission, plaintiff engaged in no speech whatsoever that is at issue in this case. D.Issues Specific to Defendant Spencer For the reasons enunciated above, defendant Spencer’s assertion that any claim against him must be dismissed, because he had no power to hire or fire plaintiff, must fail. Se 208 (2d Cir.1995) (<HOLDING>). E. Issues Specific to Defendant City of
holding that a transfer of job duties can constitute an adverse employment action holding a mere warning that termination is possible does not per se constitute adverse employment action holding that mere reprimand even if it does not result in actual dismissal can constitute adverse employment action holding that the decision to reprimand or transfer an employee if rescinded before the employee suffers a tangible harm is not an adverse employment action holding that the action taken need not be the substantial equivalent of dismissal in order to constitute adverse employment action