On December 20, 2023 a
Party Notice
was filed
involving a dispute between
Tatiana Rosado,
and
Good Shepherd Services,
Jess Dannhauser
In His Official Capacity As Commissioner Of New York City Administration For Children'S Services,
Michelle Yanche
Chief Executive Officer Of Good Shepherd Services,
Nyc Administration For Children'S Services,
for Special Proceedings - CPLR Article 78
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 12/20/2023 03:49 PM INDEX NO. 453323/2023
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/20/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
In the Matter of a Proceeding for a Judgment
Pursuant to Article 78 of the Civil Practice Law and Rules
TATIANA ROSADO
Petitioner, Index No. 4 5 3 3 2 3 / 2 0 2 3
AFFIRMATION
-against-
NEW YORK CITY ADMINISTRATION FOR
CHILDREN’S SERVICES, JESS DANNHAUSER, in his
official capacity as Commissioner of New York City
Administration for Children’s Services; and GOOD
SHEPHERD SERVICES; and, MICHELLE YANCHE,
Chief Executive Officer of GOOD SHEPHERD SERVICES
Respondents.
Betsy Kramer, an attorney duly admitted to practice law before the Courts of the State of New
York affirms the following under penalty of perjury:
1. I am a staff attorney and Director of Special Litigation at Lawyers For Children
Inc. (LFC). LFC was assigned by the Family Court of the State of New York to serve as attorney
for Tatiana Rosado (Tatiana) in all proceedings relating to her foster care placement, and I am
fully familiar with the facts and circumstances of this matter.
2. I submit this Affirmation in support of the Order to Show Cause and temporary
restraining order preventing the discharge of Tatiana from foster care while this matter is
pending.
3. In matters pertaining to Tatiana’s foster care placement, the Administration for
Children’s Services and Good Shepherd Services and their employees have been represented by
attorneys from the Administration for Children’s Services (ACS).
1 of 2
FILED: NEW YORK COUNTY CLERK 12/20/2023 03:49 PM INDEX NO. 453323/2023
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/20/2023
4. On December 20, 2023, I provided Katherine Aquino, the ACS attorney assigned
to this matter, with a copy of the papers filed with the court today – including the draft Order to
Show Cause with the restraining order.
5. In response, Ms. Aquino said that her client still intended to discharge Tatiana
from foster care on December 21, 2023 and “we did receive the OTSC and Petition LFC plans to
file tomorrow and we will respond.”
6. Following that message, I received no further correspondence from her.
Dated: New York, New York
December 20, 2023
Betsy Kramer, Esq.
Lawyers For Children, Inc.
110 Lafayette Street, 8th floor
New York, New York 10013
Tel. (212) 966-6420
Fax. (212) 966-0531
BKramer@LawyersForChildren.org
2 of 2
Document Filed Date
December 20, 2023
Case Filing Date
December 20, 2023
Category
Special Proceedings - CPLR Article 78
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: NEW YORK COUNTY CLERK 12/20/2023 03:49 PM INDEX NO. 453323/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/20/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK In the Matter of a Proceeding for a Judgment Pursuant to Article 78 of the Civil Practice Law and Rules TATIANA ROSADO Petitioner, Index No. 4 5 3 3 2 3 / 2 0 2 3 AFFIRMATION -against- NEW YORK CITY ADMINISTRATION FOR CHILDREN’S SERVICES, JESS DANNHAUSER, in his official capacity as Commissioner of New York City Administration for Children’s Services; and GOOD SHEPHERD SERVICES; and, MICHELLE YANCHE, Chief Executive Officer of GOOD SHEPHERD SERVICES Respondents. Betsy Kramer, an attorney duly admitted to practice law before the Courts of the State of New York affirms the following under penalty of perjury: 1. I am a staff attorney and Director of Special Litigation at Lawyers For Children Inc. (LFC). LFC was assigned by the Family Court of the State of New York to serve as attorney for Tatiana Rosado (Tatiana) in all proceedings relating to her foster care placement, and I am fully familiar with the facts and circumstances of this matter. 2. I submit this Affirmation in support of the Order to Show Cause and temporary restraining order preventing the discharge of Tatiana from foster care while this matter is pending. 3. In matters pertaining to Tatiana’s foster care placement, the Administration for Children’s Services and Good Shepherd Services and their employees have been represented by attorneys from the Administration for Children’s Services (ACS). 1 of 2 FILED: NEW YORK COUNTY CLERK 12/20/2023 03:49 PM INDEX NO. 453323/2023 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/20/2023 4. On December 20, 2023, I provided Katherine Aquino, the ACS attorney assigned to this matter, with a copy of the papers filed with the court today – including the draft Order to Show Cause with the restraining order. 5. In response, Ms. Aquino said that her client still intended to discharge Tatiana from foster care on December 21, 2023 and “we did receive the OTSC and Petition LFC plans to file tomorrow and we will respond.” 6. Following that message, I received no further correspondence from her. Dated: New York, New York December 20, 2023 Betsy Kramer, Esq. Lawyers For Children, Inc. 110 Lafayette Street, 8th floor New York, New York 10013 Tel. (212) 966-6420 Fax. (212) 966-0531 BKramer@LawyersForChildren.org 2 of 2