Complaint,Petition: St v. Brewster Central School District

On May 25, 2021 a Complaint,Petition was filed involving a dispute between St, T. S., and Brewster Central School District, for Torts - Child Victims Act in the District Court of Putnam County.

Preview
FILED: PUTNAM COUNTY CLERK 05/25/2021 11:50 AM INDEX NO. 500754/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/25/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF PUTNAM
X
T.S., Date Index No. Purchased:

Plaintiff, Index No.:
-against-
Plaintiff designates PUTNAM
BREWSTER CENTRAL SCHOOL DISTRICT, County as the place of trial.

Defendant. The basis of venue is
X Defendant’s residence.

SUMMONS

The Above-Named Defendant:

YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
appearance, on the Plaintiff’s Attorney(s) within twenty (20) days after the service of this
summons, exclusive of the day of service (or within thirty (30) days after the service is complete
if this summons is not personally delivered to you within the State of New York); and in case of
your failure to appear or answer, judgment will be taken against you by default for the relief
demanded in the complaint.

Dated: New York, New York
May 25, 2021

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TO: BREWSTER CENTRAL DISTRICT
30 Farm to Market Road
Brewster, New York 10509

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF PUTNAM
X
T.S., Date Filed:
Index No.:
Plaintiff,
-against-
VERIFIED COMPLAINT
BREWSTER CENTRAL SCHOOL DISTRICT,

Defendant.

Plaintiff, T.S., by his attorneys, Slater Slater Schulman LLP, brings this action against:

BREWSTER CENTRAL DISTRICT (“District”); and alleges, on personal knowledge as to

himself and on information and belief as to all other matters, as follows:

JURISDICTION AND VENUE

1. This action is brought pursuant to the Child Victims Act (“CVA”). See CPLR §

214-g and 22 NYCRR 202.72; as it alleges physical, psychological and emotional

injuries/damages suffered as a result of conduct against an infant that constitutes one or more

sexual offenses as defined in Article 130 of the New York Penal Law, including without limitation,

conduct constituting rape (consisting of sexual intercourse) (N.Y. Penal Law §§ 130.25 - 130.35);

criminal sexual act (consisting of oral or anal sexual conduct) (N.Y. Penal Law §§ 130.40- 130.53),

and/or sexual abuse (consisting of sexual contact) (N.Y. Penal Law §§ 130.55 - 130.77).

2. Whenever reference is made to any defendant entity, such reference includes that

entity, its parent companies, subsidiaries, affiliates, predecessors, and successors. In addition,

whenever reference is made to any act, deed, or transaction of any entity, the allegation means that

the entity engaged in the act, deed, or transaction by or through its officers, directors, agents,

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employees, or representatives while they were actively engaged in the management, direction,

control, or transaction of the entity’s business affairs.

3. This Court has personal jurisdiction over Defendant pursuant to CPLR 301 and 302,

in that Defendant resides in New York and/or conducts or, at relevant times conducted, activities

in the State of New York that give rise to the claims asserted herein.

4. This Court has jurisdiction over this action because the amount of damages Plaintiff

seeks exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction.

5. Venue for this action is proper in the County of Putnam pursuant to CPLR § 503 in

that Defendant resides in this County and all the events and/or omissions giving rise to the claims

asserted herein occurred here.

PARTIES

6. Plaintiff, T.S., (“Plaintiff”) is a sixty-eight (68) year old individual residing in

Putnam County, New York. Plaintiff experienced sexual abuse in or around the year 1960 when

Plaintiff was approximately eight (8) years old.

7. At all times herein, District maintains its principal place of business at 30 Farm to

Market Road, Brewster, New York 10509.

8. At all times herein, the District is responsible for managing and directing the public

schools within its district and/or jurisdiction.

9. At all times herein, Garden Street School (“School”) maintained its principal place

of business at 20 Garden Street, Brewster, New York, 10509.

10. At all times herein, the School was a public school operating within the jurisdiction

of the Defendant District.

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11. At all times material to the Complaint, the District, through its agents, servants,

and/or employees had control over those activities involving children.

12. At all times material to the Complaint, the District had the power to employ

individuals working with and/or alongside children within the District, including but not limited

to those at the School.

13. At all times material to the Complaint, School was a public educational institution

within New York State.

14. At all times material to the Complaint, School was a public educational institution

operating under the control of the Defendant District.

15. At all times material to the Complaint, School was a public educational institution

operating for the benefit of the Defendant District.

16. At all times material to the Complaint, Defendant District owned, managed,

operated, controlled, staffed, hired/fired employees of, and/or maintained School.

17. Upon information and belied, School closed in 1998.

18. At all times material to the Complaint, Ms. Schoenfeld (“Abuser”) was an agent,

servant, and/or employee of District.

19. At all times material to the Complaint, Abuser was an agent, servant, and/or

employee of School.

20. At all times material to the Complaint, Abuser was a teacher at School.

21. At all times material to the Complaint, while an agent, servant and/or employee of

the Defendant District and School, Abuser remained under the control and supervision of District

and School.

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22. District and School placed Defendant Abuser in positions where Abuser had

immediate access to children.

UNDERLYING FACTS AND ALLEGATIONS

23. In or around the year of 1960, when the then infant Plaintiff was approximately

eight (8) years old, Plaintiff attended School, a public school under the authority of Defendant

District.

24. The Plaintiff was born in July of 1952.

25. At all times herein, Abuser was an adult.

26. During and through the aforementioned activities, Plaintiff, as a minor and

vulnerable child, was dependent on the District, School and Abuser.

27. During and through these activities, Defendant had custody of Plaintiff and

accepted the entrustment of the then infant Plaintiff.

28. During and through these activities, Defendant had responsibility of, and authority

over, the then infant Plaintiff.

29. Defendant assumed duties to protect the then infant Plaintiff from harms arising

under the doctrine of in loco parentis.

30. Through Abuser’s position at, within, or for the School and/or District, Abuser was

put in direct contact with Plaintiff, a student in the District. It was under these circumstances that

Plaintiff came to be under the direction, contact, and control of Abuser, who used his position of

authority and trust over Plaintiff to manipulate, sexually abuse and sexually harass the then infant

Plaintiff.

31. On numerous occasions, in or about the year of 1960, while Plaintiff was a minor,

Abuser, while acting as a teacher, counselor, trustee, director, officer, employee, agent, servant

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and/or volunteer of Defendant herein, sexually assaulted, sexually abused and/or had sexual

contact with Plaintiff in violation of the laws of the State of New York, including New York’s

Penal Law Article 130.

32. Specifically, the abuse included, but was not limited to, mutual genital fondling,

touching and/or groping and forcing then infant Plaintiff to perform oral sex on Abuser.

33. The aforementioned sexual abuse occurred at the School.

34. Plaintiff’s relationship to the School, as a vulnerable child and participant in School

activities, was one in which Plaintiff was subject to the School’s ongoing influence.

35. At all times material hereto, Abuser was under the direct supervision, employ

and/or control of the District.

36. At all times material hereto, Abuser was under the direct supervision, employ

and/or control of the School.

37. The School knew and/or reasonably should have known, and/or knowingly

condoned, and/or covered up, the inappropriate and unlawful sexual activities of Abuser who

sexually abused Plaintiff.

38. The District knew and/or reasonably should have known, and/or knowingly

condoned, and/or covered up, the inappropriate and unlawful sexual activities of Abuser who

sexually abused Plaintiff.

39. The School negligently or recklessly believed that Abuser was fit to work with

children and/or that any previous problems he had were fixed and cured; that Abuser would not

sexually molest children; and that Abuser would not injure children.

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40. The District negligently or recklessly believed that Abuser was fit to work with

children and/or that any previous problems he had were fixed and cured; that Abuser would not

sexually molest children; and that Abuser would not injure children.

41. The School had the responsibility to supervise and/or direct its employees and/or

agents serving at the School, and specifically, had a duty not to aid individuals such as Abuser, by

assigning, maintaining and/or appointing Abuser to a position with access to minors.

42. The District had the responsibility to supervise and/or direct its employees and/or

agents serving at the School, and specifically, had a duty not to aid individuals such as Abuser, by

assigning, maintaining and/or appointing Abuser to a position with access to minors.

43. By holding Abuser out as safe to work with children, and by undertaking the

custody, supervision of, and/or care of the minor Plaintiff, School entered into a fiduciary

relationship with the minor Plaintiff. As a result of Plaintiff being a minor, and by the School’s

undertaking the care and guidance of the vulnerable minor Plaintiff, the School held a position of

empowerment over Plaintiff.

44. By holding Abuser out as safe to work with children, and by undertaking the

custody, supervision of, and/or care of the minor Plaintiff, District entered into a fiduciary

relationship with the minor Plaintiff. As a result of Plaintiff being a minor, and by District’s

undertaking the care and guidance of the vulnerable minor Plaintiff, District held a position of

empowerment over Plaintiff.

45. School, by holding itself out as being able to provide a safe environment for

children, solicited and/or accepted this position of empowerment. This empowerment prevented

the then minor Plaintiff from effectively protecting himself. School thus entered into a fiduciary

relationship with Plaintiff.

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46. District, by holding itself out as being able to provide a safe environment for

children, solicited and/or accepted this position of empowerment. This empowerment prevented

the then minor Plaintiff from effectively protecting himself. The District thus entered into a

fiduciary relationship with Plaintiff.

47. School had a special relationship with Plaintiff.

48. District had a special relationship with Plaintiff.

49. School owed Plaintiff a duty of reasonable care because School had knowledge

about the risk that Abuser posed to Plaintiff, the risk of abuse in general in its programs, and/or

the risks that its facilities posed to minor children.

50. District owed Plaintiff a duty of reasonable care because District had knowledge

about the risk that Abuser posed to Plaintiff, the risk of abuse in general in its programs, and/or

the risks that its facilities posed to minor children.

51. School and District owed Plaintiff a duty of reasonable care because they solicited

youth and parent(s) and/or guardian(s) for participation in their youth programs; encouraged youth

and parent(s) and/or guardian(s) to have the youth participate in their programs; undertook custody

of minor children, including Plaintiff; promoted their facilities and programs as being safe for

children; held their agents, including Abuser, out as safe to work with children; encouraged parents

and/or guardians and children to spend time with their agents; and/or encouraged their agents,

including Abuser, to spend time with, interact with, and recruit children.

52. School owed Plaintiff a duty to protect Plaintiff from harm because School’s

actions created a foreseeable risk of harm to Plaintiff.

53. District owed Plaintiff a duty to protect Plaintiff from harm because District’s

actions created a foreseeable risk of harm to Plaintiff.

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54. At all times relevant and material hereto, Defendant, and/or Defendant’s agents or

employees, were responsible and/or liable for each other’s negligent actions and/or omissions, via

including but not limited to respondeat superior. However, Plaintiff does not allege that the

doctrine of respondeat superior applies directly to intentional acts of sexual assault or sexual abuse

alleged of the individual perpetrator(s) identified in this complaint.

55. School’s breach of its duties include, but are not limited to: failure to have sufficient

policies and procedures to prevent child sexual abuse, failure to properly implement the policies

and procedures to prevent child sexual abuse, failure to take reasonable measures to make sure that

the policies and procedures to prevent child sexual abuse were working, failure to adequately

inform families and children of the risks of child sexual abuse, failure to investigate risks of child

sexual abuse, failure to properly train the workers at institutions and programs within the School,

geographical confines, failure to protect children in their programs from child sexual abuse, failure

to adhere to the applicable standard of care for child safety, failure to investigate the amount and

type of information necessary to represent the institutions, programs, leaders and people as safe,

failure to train their employees properly to identify signs of child molestation by fellow employees,

failure by relying on mental health professionals, and/or failure by relying on people who claimed

that they could treat child molesters.

56. District’s breach of its duties include, but are not limited to: failure to have

sufficient policies and procedures to prevent child sexual abuse, failure to properly implement the

policies and procedures to prevent child sexual abuse, failure to take reasonable measures to make

sure that the policies and procedures to prevent child sexual abuse were working, failure to

adequately inform families and children of the risks of child sexual abuse, failure to investigate

risks of child sexual abuse, failure to properly train the workers at institutions and programs within

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the District, geographical confines, failure to protect children in their programs from child sexual

abuse, failure to adhere to the applicable standard of care for child safety, failure to investigate the

amount and type of information necessary to represent the institutions, programs, leaders and

people as safe, failure to train their employees properly to identify signs of child molestation by

fellow employees, failure by relying on mental health professionals, and/or failure by relying on

people who claimed that they could treat child molesters.

57. School also breached its duties to Plaintiff by failing to warn Plaintiff and Plaintiff’s

family of the risk that Abuser posed and the risks of child sexual abuse by its employees and/or

agents. School also failed to warn Plaintiff about any of the knowledge that it had about child

sexual abuse.

58. District also breached its duties to Plaintiff by failing to warn Plaintiff and

Plaintiff’s family of the risk that Abuser posed and the risks of child sexual abuse by its employees

and/or agents. District also failed to warn Plaintiff about any of the knowledge that it had about

child sexual abuse.

59. School also violated a legal duty by failing to report known and/or suspected abuse

of children by Abuser and/or its other agents to the police and law enforcement.

60. District also violated a legal duty by failing to report known and/or suspected abuse

of children by Abuser and/or their other agents to the police and law enforcement.

61. By employing Abuser at School, and other facilities under its supervision, District,

through its agents, affirmatively represented to minor children and their families that Abuser did

not pose a threat to children, did not have a history of molesting children, that the District did not

know that Abuser had a history of molesting children, and that District did not know that Abuser

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was a danger to children. Plaintiff and Plaintiff’s family were induced to rely on these affirmations

and did rely on them.

62. By employing Abuser at School, School through its agents, affirmatively

represented to minor children and their families that Abuser did not pose a threat to children, did

not have a history of molesting children, that School did not know that Abuser had a history of

molesting children, and that School did not know that Abuser was a danger to children. Plaintiff

and Plaintiff’s family were induced to rely on these affirmations and did rely on them.

63. School violated various New York statutes, including, but not limited to N.Y. Soc.

Serv. Law §§ 413 and 420, which require school officials and teachers to report suspected cases

of child abuse and impose liability for failure to report.

64. District violated various New York statutes, including, but not limited to N.Y. Soc.

Serv. Law §§ 413 and 420, which require school officials and teachers to report suspected cases

of child abuse and impose liability for failure to report.

65. The injuries and damages suffered by Plaintiff are specific in kind to Plaintiff and

special, peculiar, and above and beyond those injuries and damages suffered by the public.

NATURE OF ALLEGED CONDUCT

66. This action alleges physical, psychological and emotional injuries suffered as a

result of conduct which would constitute a sexual offense on a minor as defined in Article 130 of

the New York Penal Law, including without limitation, conduct constituting rape (consisting of

sexual intercourse) (N.Y. Penal Law§§ 130.25 - 130.35); criminal sexual act (consisting of oral or

anal sexual conduct) (N.Y. Penal Law§§ 130.40 - 130.53), and/or sexual abuse (consisting of

sexual contact) (N.Y. Penal Law§§ 130.55 - 130.77).

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67. The limitation of liability set forth in CPLR Art. 16 is not applicable to the claim

of personal injury alleged herein, by reason of one or more of the exemptions provided in CPLR

§ 1602, including without limitation, that Defendants acted with reckless disregard for the safety

Plaintiff, or knowingly or intentionally, in concert with its agents and employees, to retain and

permit the abuser mentioned herein unfettered and prolonged unsupervised access to children.

COUNT I – NEGLIGENCE

68. Plaintiff repeats and realleges by reference each and every allegation set forth above

as if fully set forth herein.

69. Defendant breached its aforementioned duties that were owed to the Plaintiff and

were otherwise negligent.

70. As a result of Defendant’s conduct described herein, constituting negligence and/or

gross negligence, Plaintiff has and will continue to suffer personal physical and psychological

injuries, including but not limited to great pain of mind and body; severe and permanent emotional

distress; physical manifestations of emotional distress; problems sleeping and concentrating; low

self-confidence, low self-respect, and low self-esteem; feeling of worthlessness, shamefulness, and

embarrassment; feeling alone and isolated; losing faith in authority figures; struggling with alcohol

problems; feeling helpless and hopeless; problems with sexual intimacy; relationship problems;

trust issues; feeling confused and angry; depression; anxiety; feeling dirty, used, and damaged;

having traumatic flashbacks; and feeling that his childhood and innocence was stolen. Plaintiff

was prevented and will continue to be prevented from performing Plaintiff’s normal daily

activities. As a victim of Defendant’s misconduct, Plaintiff is unable at this time to fully describe

all the details of that abuse and the extent of the harm Plaintiff suffered as a result.

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71. Defendant’s acts and conduct showed a reckless or willful disregard for the safety

and well-being of Plaintiff and other children.

72. By reason of the foregoing, Defendant is liable to Plaintiff for compensatory

damages, and for punitive damages (non-municipal Defendants), together with interest and costs.

COUNT II - NEGLIGENT HIRING, SUPERVISION, RETENTION, AND/OR
DIRECTION

73. Plaintiff repeats and realleges by reference each and every allegation set forth above

as if fully set forth herein.

74. At all times herein, School hired Abuser.

75. At all times herein, District hired Abuser.

76. School hired Abuser for positions that required her to work closely with, mentor,

supervise and counsel young boys and girls.

77. District hired Abuser for positions that required her to work closely with, mentor,

supervise and counsel young boys and girls.

78. Defendant herein was negligent in hiring Abuser because Defendant knew or

should have known, through the exercise of reasonable care, of Abuser’s propensity to develop

inappropriate relationships with children in Defendant’s charge and to engage in sexual behavior

and lewd and lascivious conduct with such children.

79. Abuser would not and could not have been in a position to sexually abuse Plaintiff

had Abuser not been hired by the Defendant to mentor, teach, supervise and counsel children.

80. Abuser continued to sexually abuse Plaintiff while at or around the School.

81. The harm complained of was foreseeable.

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82. Plaintiff would not have suffered the foreseeable harm complained of herein but for

the negligence of the Defendant in having placed Abuser and/or allowed Abuser to remain in his

position.

83. At all times while Abuser was employed or appointed by School, he was supervised

by the Defendant herein and/or Defendant’s agents and employees.

84. At all times while Abuser was employed or appointed by School, he was under the

direction of, and/or answerable to, the Defendant’s agents and employees.

85. At all times while Abuser was employed or appointed by District, he was

supervised by Defendant herein and/or Defendant’s agents and employees.

86. At all times while Abuser was employed or appointed by District, he was under the

direction of, and/or answerable to, the Defendant’s agents and employees.

87. Defendant was negligent in its direction and/or supervision of Abuser in that it

knew or should have known, through the exercise of ordinary care, that Abuser’s conduct would

subject third parties to an unreasonable risk of harm, including Abuser’s propensity to develop

inappropriate relationships with children under his charge and to engage in sexual behavior and

lewd and lascivious conduct with such children.

88. Defendant failed to take steps to prevent such conduct from occurring.

89. Defendant was negligent in its retention of Abuser in that it knew, or should have

known, through the exercise of reasonable care, of Abuser’s propensity to develop inappropriate

relationships with children under his charge and to engage in sexual behavior and lewd and

lascivious conduct with such children.

90. Defendant retained Abuser in his positions as mentor, teacher, supervisor, coach

and counselor to such children and thus left her in a position to continue such behavior.

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91. Defendant was further negligent in its retention, supervision, and/or direction of

Abuser allowing her to sexually molest Plaintiff on the Defendant’s premises.

92. Defendant failed to take reasonable steps to prevent such events from occurring on

Defendant’s premises.

93. Abuser would not and could not have been in a position to sexually abuse Plaintiff

had he not been negligently retained, hired, supervised, and/or directed by the Defendant as a

mentor, teacher, supervisor, coach and counselor to the infant Plaintiff and other children at the

School.

94. Defendant breached its duty of care to the Plaintiff and was otherwise negligent.

95. As a direct and/or indirect result of said conduct/negligence, Plaintiff has suffered

the injuries and damages described herein.

96. By reason of the foregoing, Defendant is liable to Plaintiff for compensatory

damages, and for punitive damages (non-municipal Defendants), together with interest and costs.

COUNT III - BREACH OF STATUTORY DUTY TO REPORT ABUSE UNDER
SOC. SERV. LAW §§ 413 and 420

97. Plaintiff repeats and realleges by reference each and every allegation set forth above

as if fully set forth herein.

98. Pursuant to N.Y. Soc. Serv. Law §§ 413 and 420, Defendant, by and through,

including but not limited to its principals, agents and/or employees, had a statutorily imposed duty

to report or cause to report abuse or maltreatment of children in its care or children and/or parents,

guardians, custodians or other persons legally responsible for such children that otherwise came

before them in their official capacity, when Defendants had reasonable cause to suspect abuse or

maltreatment of such children.

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99. Defendant breached that duty by negligently, knowingly and/or willfully failing to

report or causing to report reasonable suspicion of abuse or maltreatment of such children, and

Plaintiff in particular.

100. As a direct and/or indirect result of said conduct, Plaintiff has suffered injuries and

damages described herein.

101. By reason of the foregoing, Defendant is liable to Plaintiff for compensatory

damages, and for punitive damages (non-municipal Defendants), together with interest and costs.

102. The sexual abuse of Plaintiff was extreme and outrageous conduct, beyond all

possible bounds of decency, atrocious and intolerable in a civilized community.

103. By reason of the foregoing sexual contact, Plaintiff has suffered harms as more

fully alleged herein, including emotional trauma and related continuing psychological sequela.

104. The limitations of liability set forth in Article 16 of the CPLR do not apply to any

of the causes of action alleged in this Complaint.

WHEREFORE, it is respectfully requested that the Court grant judgment in this action in

favor of the Plaintiff, and against Defendant, in a sum of money in excess of the jurisdictional

limits of all lower courts which would otherwise have jurisdiction, together with all applicable

interest, costs, disbursements, as well as punitive damages against non-municipal defendants and

such other, further and different relief as the Court in its discretion shall deem to be just, proper

and equitable.

Plaintiff further places Defendant on notice and reserves the right to interpose claims

sounding in Fraudulent Concealment, Deceptive Practices and/or Civil Conspiracy should the facts

and discovery materials support such claims.

Dated: New York, New York
May 25, 2021

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ATTORNEY'S VERIFICATION

Adam P. Slater, an attorney duly admitted to practice law in the Courts of the State of

New York, hereby affirms the following statements to be true under the penalties of perjury,

pursuant to Rule 2106 of the CPLR:

Your affirmant is a partner of SLATER SLATER SCHULMAN, LLP, attorneys for the

Plaintiff in the within action;

That he has read the foregoing Summons & Complaint and knows the contents thereof;

that the same is true to his own knowledge, except as to the matters therein stated to be alleged

upon information and belief, and that as to those matters he believes it to be true.

Affirmant further states that the source of his information and the grounds for his belief

are derived from interviews with the Plaintiff and from the file maintained in the normal course

of business.

Affirmant further states that the reason this verification is not made by the Plaintiff is that

the Plaintiff is not presently within the County of New York, which is the county wherein the

attorneys for the Plaintiff herein maintain their offices.

Dated: New York, New York
May 25, 2021

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SUPREME COURT OF THE STATE NEW YORK
COUNTY OF PUTNAM
---------------------------------------------------------------------X
T.S., Index No.:

Plaintiff,
-against-

BREWSTER CENTRAL SCHOOL DISTRICT,

Defendant.
--------------------------------------------------------------------X

SUMMONS & VERIFIED COMPLAINT

Slater Slater Schulman LLP
Attorneys for Plaintiff
488 Madison Avenue, 20th Floor
New York, New York 10022
(212) 922-0906

CERTIFICATION

Pursuant to 22 NYCRR §130-1.1-a, the undersigned, an attorney duly admitted to practice in the courts of
the State of New York, certifies that, upon information and belief, and reasonable inquiry, the contentions contained
in the annexed document are not frivolous as defined in subsection (c) of the aforesaid section.

__________________________
Adam P. Slater, Esq.

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Case Info

Judge

Leonard D Steinman Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

May 25, 2021

Case Filing Date

May 25, 2021

County

Parties

BANKS, STEVEN LEON Attorney for the Defendant
Brewster Central School District Defendant
Brewster Central School District Defendant
LEDER, LINC Attorney for the Plaintiff
PAKRUL, MARC CHRISTOPHER Attorney for the Defendant
ROMANELLO, DIANA MARIE Attorney for the Plaintiff
SIBOVITS, DANIT LEENOR Attorney for the Defendant
SLATER, JOSEPH M Attorney for the Plaintiff
St Plaintiff
T. S. Plaintiff
T. S. Plaintiff
WEISSLITZ, EMILY R Attorney for the Defendant
ADAM SLATER Attorneys for Plaintiffs
CHRISTIAN CURRAN Attorneys for Plaintiffs

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Complaint,Petition: St v. Brewster Central School District

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