Usman Makhdoom v. Darul-Uloom Al-Madania, Inc., Ismail Memon, John Does 1-5

Pursuant to CPLR 214-g, New York’s Child Victims Act (the “CVA”), Plaintiff

brings this revival action to vindicate his rights. The CVA historically opened a period for victims

and survivors of childhood sexual abuse in the State of New York to pursue claims that would

otherwise be untimely.

Plaintiff Usman Makhdoom is a 40-year-old resident of Ontario, Canada.

From or about September 1994 to or about August 1995 Plaintiff attended and lived

at Defendant Darul-Uloom Al-Madania, Inc.’s Boys’ School in Buffalo, New York, during the

academic years.

During his time as a student from the approximate ages of 13 to 14 years old,

Plaintiff was sexually abused and sexually assaulted by Ismail Memon, the founder of the Boys’

School, its principal and/or headmaster.

Beginning when Plaintiff was approximately 13 years old Memon summoned

Plaintiff to his office inside of the school mosque where Memon told Plaintiff “come here so I

can show love to you” in Urdu before sexually assaulting Plaintiff by fondling and manipulating