Вы находитесь на странице: 1из 246

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK


X
ANASTASIA STAPON,

Plaintiff,

-against-

RIVERHEAD CENTRAL SCHOOL DISTRICT, VERIFIED COMPLAINT


CHARLES REGAN, AURELIA L. HENRIQUEZ,
SUSAN KOUKOUNAS, CHRISTOPHER DORR,
LAURIE DOWNS, GREGORY MEYER,
ELIZABETH C. SILVA, THERESE ZUHOSKI a/k/a
THERESE FERGUSON, BRIAN CONNELLY,
PAUL R. DOYLE, JOSEPH OGEKA, JR.,
NANCY CARNEY, JAMES MCCAFFREY,
LORI M. HULSE, NANCY GASSERT,
W. BRIAN STARK, KATHLEEN BEREZNY,
ELLEN HARKIN, TIMOTHY GRIFFING,
CHRISTINE PRETE, and ANGELA DEVITO,

Defendants.
X

Plaintiff, ANASTASIA STAPON, by her attorneys, Ray,‘Mitev & Associates, LLP,

appears and complains as follows:

PARTIES

I. At all relevant times, Plaintiff is over the age of 18 and resides in the County of

Suffolk.

2. At all relevant times, upon information and belief, Riverhead Central School

District (hereafter “RCSD”) is a New York State public school district created and existing under

and by virtue of the laws of the State of New York, with offices in and located in Suffolk

County, New York.

3. At all relevant times, Riverhead High School was and is a public school operating

as a high school in the Riverhead Central School District.


4. At all relevant times, individual Defendants are or were agents or employees of

Riverhead Central School District.

5. In the school year 2018-2019, Defendant Aurelia L. Henriquez was and is

Superintendent of Riverhead Central School District.

6. Upon information and belief, at all relevant times, Defendant Aurelia L.

Henriquez was and is a resident of Suffolk County, New York.

7. In the school year 2018-2019, Defendant Susan Koukounas was President of the

Board of Education for Riverhead Central School District.

8. Upon information and belief, at all relevant times, Defendant Susan Koukounas

was and is a resident of Suffolk County, New York.

9. In the school year 2018—2019, Defendant Christopher Dorr was Vice President of

the Board of Education for Riverhead Central School District.

10. Upon information and belief, at all relevant times, Defendant Christopher Dorr

was and is a resident of Suffolk County, New York.

11. In the school year 2018—2019, Defendant Laurie Downs was a member of the

Board of Education for Riverhead Central School District.

12. Upon information and belief, at all relevant times, Defendant Laurie Downs was

and is a resident of Suffolk County, New York.

13. In the school year 2018—2019, Defendant Gregory Meyer was a member of the

Board of Education for Riverhead Central School District.

14. Upon information and belief, at all relevant times, Defendant Gregory Meyer was

and is a resident of Suffolk County, New York.


15. In the school year 2018-2019, Defendant Elizabeth C. Silva was a member of the

Board of Education for Riverhead Central School District.

16. Upon information and belief, at all relevant ”times, Defendant Elizabeth C. Silva

was and is a resident of Suffolk County, New York.

17. In the school year 2018-2019, Defendant Therese Zuhoski was a member of the

Board of Education for Riverhead Central School District.

18. Upon information and belief, at all relevant times, Defendant Therese Zuhoski

was and is a resident of Suffolk County, New York.

19. In the school year 2018—2019, Defendant Brian Connelly was a member of the

Board of Education for Riverhead Central School District.

20. Upon information and belief, at all relevant times, Defendant Brian Connelly was

and is a resident of Suffolk County, New York.

21. In the school year 2018—2019, Defendant Charles Regan was Principal of

Riverhead High School.

22. Upon information and belief, Charles Regan was hired as Assistant Principal of

Riverhead High School in or about June 2006.

23. Upon information and belief, Charles Regan was hired on an “Emergency 20—day

Conditional Appointment,” and that at that time of his hiring, Charles Regan’s resume and level

of expertise was neither seen by, nor known by, at least one member on the Board of Education

for Riverhead Central School District.

24. Upon information and belief, Charles Regan’s employment as an agent or

employee of Riverhead Central School District was approved by the Superintendent of


Riverhead Central School District, and by the Board of Education for Riverhead Central School

District, at a Board of Education meeting having taken place on June 27, 2006.

25. Upon information and belief, Charles Regan’s employment as an agent or

employee of the Riverhead Central School District became effective on or about July 1, 2006.

26. Upon information and belief, at all relevant times, Charles Regan was and is a

resident of Suffolk County.

27. In or about June 2006, upon information and belief, Defendant Paul R. Doyle was

Superintendent of Riverhead Central School District.

28. Upon information and belief, at all relevant times, Defendant Paul R. Doyle was

and is a resident of Suffolk County, New York.

29. In or about June 2006, upon information and belief, Defendant Joseph Ogeka, Jr.

was Assistant Superintendent for Personnel and Community for Riverhead Central School

District.

30. Upon information and belief, at all relevant times, Defendant Joseph Ogeka, Jr.

was and is a resident of Suffolk County, New York.

31. In the school years 2005-2007, upon information and belief, Defendant Nancy

Carney was Assistant Superintendent for Curriculum & Instruction for Riverhead Central School

District.

32. Upon information and belief, at all relevant times, Defendant Nancy Carney was

and is a resident of Suffolk County, New York.

33. In the school years 2004-2006, upon information and belief, Defendant James

McCaffrey was Principal of Riverhead High School.


34. Upon information and belief, at all relevant times, Defendant James McCaffrey

was and is a resident of Suffolk County, New York.

35. In the school year 2005 ~2006, upon information and belief, Defendant Lori M.

Hulse was President of the Board of Education for Riverhead Central School District.

36. Upon information and belief, at all relevant times, Defendant Lori M. Hulse was

and is a resident of Suffolk County, New York.

37. In the school year 2005-2006, upon information and belief, Defendant Nancy G.

Gassert was Vice President of the Board of Education for Riverhead Central School District.

38. In the school year 2006-2007, upon information and belief, Defendant Nancy G.

Gassert was President of the Board of Education for Riverhead Central School District.

39. Upon information and belief, at all relevant times, Defendant Nancy G. Gassert

was and is a resident of Suffolk County, New York.

40. In the school year 2005-2006, upon information and belief, Defendant W. Brian

Stark was a member of the Board of Education for Riverhead Central School District.

41. In the school year 2006—2007, upon information and belief, Defendant W. Brian

Stark was Vice President of the Board of EduCation for Riverhead Central School District.

42. Upon information and belief, at all relevant times, Defendant W. Brian Stark was

and is a resident of Suffolk County, New York.

43. In the school years 2005-2007, upon information and belief, Defendant Kathleen

Berezny was a member of the Board of Education for Riverhead Central School District.

44. Upon information and belief, at all relevant times, Defendant Kathleen Berezny

was and is a resident of Suffolk County, New York.


45. In the school years 2005-2007, upon information and belief, Defendant Ellen

Harkin was a member of the Board of Education for Riverhead Central School District.

46. Upon information and belief, at all relevant times, Defendant Ellen Harkin was

and is a resident of Suffolk County, New York.

47. In the school years 2005—2007, upon information and belief, Defendant Timothy

Griffing was a member of the Board of Education for Riverhead Central School District.

48. Upon information and belief, at all relevant times, Defendant Timothy Griffing

was and is a resident of Suffolk County, New York.

49. In the school years 2005—2007, upon information and belief, Defendant Christine

Prete was a member of the Board of Education for Riverhead Central School District.

50. Upon information and belief, at all relevant times, Defendant Christine Prete was

and is a resident of Suffolk County, New York.

51. In the school year 2006—2007, upon information and belief, Defendant Angela

DeVito was a member of the Board of Education for Riverhead Central School District.

52. Upon information and belief, Defendant Angela DeVito was and is a resident of

Suffolk County, New York.

53. At all times herein, Plaintiff is and was a senior student in the 12th grade at

Riverhead High School.

JURISDICTION

Jurisdiction is proper because this case is brought, inter alia, pursuant to federal statutes

20 USC §168l et seq. (Title IX), and 42 USC §1983.


VENUE

Venue is properly in this District because the acts alleged herein all arose and occurred in

this District, and all the parties resided in or were located in this Eastern District of New York

when these acts arose and occurred.

ALLEGATIONS

54. In and around January 8, 2019 and continuing until April 30, 2019, Defendant

Regan exercised his position and authority and powers over students, including Plaintiff, in his

employment as the Principal of Riverhead High School.

55. From around January 8, 2019 and continuously until April 30, 2019, Defendant

Regan knowingly, willfully misused his position, authority and powers in order to sexually

harass, sexually seduce, assault, batter, and sexually abuse Plaintiff.

56. In the school year 2018-2019, Plaintiff suffered deep mental depression.

57. In the school year 2018—2019, Plaintiff had become a frequent user of marijuana

and alcohol.

58. Plaintiff would frequently use marijuana and alcohol in and out of school, before,

during and after school


hours
59. At all times herein, by reason of Plaintiff’s deep depression and use of marijuana

and alcohol, Plaintiff was in need of assistance Via teachers, administrators, a counselor and/or

mental health professional, including at least one or several to have been provided to Plaintiff in

and by Defendant District.


12:1,: ‘1; r7"
/

60. At all times herein, Defendants knew and/or should have known of Plaintiffs

aforesaid state of mind and need, and of Plaintiffs use of marijuana and alcohol.

61. At all times herein, Defendants had a duty to have learned of Plaintiffs state of

mind and need, and of Plaintiffs use of marijuana and alcohol in and out of school.

62. At all times herein, Defendants had a duty to provide Plaintiff with guidance and

assistance via teachers, a counselor and/or mental health professional including at least one or

several such professional persons, as to Plaintiffs aforesaid state of mind and need, and as to

Plaintiffs use of marijuana and alcohol in and out of school.

63. At all times herein, Defendants breached and neglected Defendants’ duties

aforesaid.

64. Instead, at all times herein, Defendants provided Plaintiff and imposed upon

Plaintiff the counseling, services and attentions of Defendant Charles Regan, a sexual predator

serving as the school principal.

65. At all times herein, Defendants knew and/or should have known that Defendant

Regan was a sexual predator who sexually preyed upon young girl students under his charge as

principal.

66. At all times herein, Defendants knew and/or should have known that Defendant

Regan had been a sexual predator who sexually preyed upon young girl students under his

charge when Defendant Regan had been employed as a teacher in South Manor schools and

Eastport/South Manor schools, and upon information and belief, when he was employed as a

teacher and “Dean” at B.O.C.E.S.


12:1,: ‘1; r7"
/

67. At all times herein, in full view and with the complicity and collusion of

Defendants, Defendant Regan sexually groomed Plaintiff for his sexual harassment, sexual

assault, battery, and abuse.

68. To effect his sexually perverse purposes, Regan gave extraordinary time and

attention to Plaintiff in full view of and with the complicity and collusion of Defendants,

misusing his position and authority as a principal to do so, with the overweening sexual

grooming tactics and purposes that Defendant Regan would:

a. Cause Plaintiff to rely solely upon Regan as her counselor and mentor;

b. Cause Plaintiff to become substantially and entirely dependent upon

Regan in Regan’s authoritative and official position, as a person in place of her

parents(“in loco parentis”), and as her father figure and father substitute who

would assist Plaintiff in coping with her depression and debilitated state of mind,

and with her use of marijuana and alcohol;

c. Cause Plaintiff to rely upon Defendant Regan to shield and protect her

from disciplinary measures in school for using marijuana or alcohol therein, and

for missing classes or portions thereof Plaintiff was otherwise obliged to attend,

and unlawfully alter her attendance record in her favor, and created and

performed Plaintiffs homework for Plaintiff, to be falsely submitted to teachers

as Plaintiff s homework;

d. Cause, cajole, persuade, inveigle, overreach and deceive Plaintiff to

develop affection for and love for Defendant Regan, and concomitant physical

and emotional attachment to and attraction for Defendant Regan;


e. Disarm Plaintiff of and suppress psychological, mental and emotional and

physical defenses which Plaintiff would otherwise have had against Defendant

Regan’s sexual grooming and sexual predatory advances and sexual conduct and

sexual grooming conduct;

f. Prepare Plaintiff and cause Plaintiff to be vulnerable to Defendant Regan’s

sexually perverse attentions and sexual predatory conduct and sexual grooming

conduct;

g. Cause, cajole, persuade, inveigle, overreach and use undue influence upon

Plaintiff to accept and engage in Defendant Regan’s sexually perverse attentions

and sexually predatory conduct and sexually grooming in school and in his office

and in texts via cell phone communication;

h. Isolate Plaintiff from her parents, sister, girlfriends and boyfriends, and

school counselors and teachers, so that the Plaintiff would be caused to

overwhelmingly give Defendant Regan her undivided attention and reliance, for

him to engage in sexual perversion sexual advances, sexually predatory conduct

and in sexual grooming as to Plaintiff;

i. Falsely and deviously convince Plaintiff that Defendant Regan would

leave his wife and children for Plaintiff in order to convince Plaintiff to accept his

sexually perverse conduct, sexual advances, sexual predatory conduct and sexual

grooming;

j. Cause Plaintiff to be in fear of Defendant Regan and Defendant Regan’s

exercise of his authority and undue influence over Plaintiff, in order that Plaintiff

would submit to Defendant Regan’s sexually perverse words and acts and

10
sexually predatory conduct and sexual grooming, and so that Plaintiff would not

reveal Defendant Regan’s sexually perverse words and acts to anyone;

k. Cause Plaintiff to be in fear of Defendant Regan’s physical violence,

including by texting Plaintiff violent threats and death threats against students

who had allegedly expressed what Defendant Regan perceived to be romantic or

personal interests in Plaintiff, and against Defendant Regan’s own six-year old

daughter of whom Regan perversely and atrociously sent a photo to Plaintiff, in

order to impress upon Plaintiff and cause Plaintiff to believe that Defendant

Regan had the capacity and will to commit such heinous acts. Defendant Regan

sought to create, and created, this impression upon Plaintiff in order to overawe

Plaintiff with fear and regard for Defendant Regan so that Plaintiff would submit

to and accept Regan’s sexually predatory conduct, sexual perverse words and

acts, and sexual grooming, and to further isolate Plaintiff and cause Plaintiff to

abandon and avoid friendships and family members; and perversely to cause

Plaintiff to believe that Defendant Regan’s small child was discardable by Regan

for all of the aforesaid reasons.

1. Cause Plaintiff to fear Defendant Regan and intimidate Plaintiff, and to

inordinately depend upon Defendant Regan, and to isolate Plaintiff by causing

Plaintiff to be separated from relationships with her friends, by walking Plaintiff

from the high school to her vehicle almost daily when the school day ended, from

January 2019 through April 29, 209.

69. In order to fulfill Defendant Regan’s aforesaid illicit, sexually perverse purposes

Defendant Regan:

ll
a. Did in fact cause Plaintiff to give up her duly assigned school counselor

and private counselor in or about January -

April 2019, and instead substituted

himself as Plaintiff’s only counselor, using his authority and the


position as

school principal, and acting as Defendants’ agent, to do so;

b. Did in fact cause Plaintiff’s sister to be moved out of Riverhead High

School and into Sagamore School, in order to isolate Plaintiff as aforesaid;

c. From January 2019 through April 29, 2019, Defendant Regan did in fact

repeatedly cause Plaintiff to enter his principal’s office at Riverhead High School

in full view of Defendants and their agents and and of the


employees security

cameras and devices, and of Defendants” agents and employees and those who

were responsible to monitor said devices thereabout, and remain therein during

school hours in full knowledge of, and with the complicity and collusion of

Defendants. This occurred on a daily basis, including at intervals several times per

day, whereupon Defendant Regan caused Plaintiff to remain in his office for

extended periods of time, using each of these visits to engage Plaintiff in

conversations designed by Regan to accomplish all of the aforesaid illicit

purposes. On many such occasions, Defendant closed his office doors in order to

carry out the aforesaid purposes without hindrance or view by other persons;

d. From January 2019 through April 2019, Regan did in fact, in full View of

Defendants, their agents and employees and of the security devices and those of

Defendants’ agents who were responsible to monitor said devices, cause the door

windows to his office to be covered with blocking or screening material such that

12
the said windows were blocked, and no one could View what occurred in

Defendant’s office when the doors were closed.


I

e. In or about April 2019, Regan grossly improperly kissed Plaintiff upon her

head while he and Plaintiff were in Regan’s office. His kiss was not requested or

invited. Regan’s purpose in delivering this kiss was for all illicit and aforesaid

purposes.

f. From January 2019 through April 29, 2019, Defendant engaged in the

improper sending and receiving of thousands of sexually charged text messages

and Facetime calls to and from Plaintiff, such that, by way of example, about at

least 12,000 were sent and received by Regan in the period 3/30/2019 through

4/29/2019. Such text messages and Facetime calls were conveyed via Regan’s

partially District-funded personal cell phone and via an official school-issued cell

phone. Such text messages and Facetime calls were sent and received during

school hours and during non-school hours, including but not limited to evening

hours, early morning hours and school vacation hours, for all of the aforesaid

sexually improper purposes.

g. From January 2019 through April 29, 2019, Defendant engaged in

numerous improper telephone calls with Plaintiff, during school hours and during

non—school hours. During such telephone calls, Defendant Regan would use

Defendants’ school landline phones, and the official school-issued cell phone and

Regan’s partially District funded personal cell phone. At all times herein Regan

received District payment characterized by Defendants as a “stipend,” for Regan’s

use of his personal cell phone in Regan’s capacity as a District-employed HS.

13
Principal. Defendants knew and should have known of Defendant Regan’s

prodigious use of District phones and Defendant Regan’s use of his District paid

for personal phone, for his inordinate telephone communication with Plaintiff.

h. From January 2019 through April 29, 2019, Regan’s text messages to

Plaintiff improperly included thousands of sexually-charged and sexually explicit

messages and photo snapshots from Regan to Plaintiff, including by way of

example, a photo of Regan’s naked body wherein his penis is covered by a

vertical thin strip of cloth; messages explicitly encouraging Plaintiff to engage in

masturbation for him and with him; messages urging Plaintiff to have sex with

Regan; messages urging Plaintiff to view pornography; messages encouraging

Plaintiff to fantasize about sex and romance with Regan and with others including

administrative colleagues. Each such text message directly gives rise to causes of

action as against Defendants, but same are too cumbersome and voluminous to

separately set forth in this complaint. The texts from 3/30/19 through 4/29/19 are

attached as Schedule 1 and made a part of this Complaint. The photos sent by

Regan to Plaintiff are attached as Schedule 2 and made part of this Complaint.

i. From January 2019 through April 29, 2019, Regan sent to Plaintiff

sexually-charged videos, including by way of example, video depiction of couples

engaged in intimate embrace and in simulated sex. Each such video gives rise to

discrete causes of action as against Defendants, but due to the nature thereof,

same are not capable of being attached to this Complaint.

j. From January 2019 through April 29, 2019, Defendant Regan sent text

messages to Plaintiff, received by Plaintiff, wherein Regan threatened to harm

14
and/or kill certain students who Regan believed had formed or were forming a

personal relationship with Plaintiff, sent by Regan for the aforesaid intentions.

k. In or about April 2019, Defendant Regan improperly and perversely sent a

photo to Plaintiff which depicted Regan’s six year old daughter. In the same

month Regan sent Plaintiff a text message wherein Regan inferred that this

daughter angered him such that he would kill his daughter which, he suggested,

would greatly please his older child. This was sent by Regan for all the perverse

reasons aforesaid.

1. From January 2019 through April 29, 2019, at various times during the

school day, upon information and belief Regan in his capacity as Principal and

agent of Defendants, altered and falsified Plaintiff‘s attendance records kept by

the Defendants to falsely indicate that Plaintiff was in attendance in school during

times when Plaintiff was not so. This was done by Regan for all of the reasons

aforesaid. The Defendants knew and should have known that Defendant Regan

had falsified Plaintiff’s attendance records as aforesaid, but instead Defendants

were complicit in and colluded in these wrongful and unlawful acts.

m. From January 2019 through April 29, 2019, at various times during the

school day, Defendant Regan performed and created Plaintiffs homework

assignments and urged and used Plaintiff to submit such work as her own to

Plaintiff’ 5 teachers, for all of the aforesaid wrongful purposes.

n. On or about 4/29/19 during the school day, Defendant Regan, in full View

of Defendants’ agents and employees, cajoled and persuaded Plaintiff to enter into

and remain in his office in order that Defendant Regan could sexually harass,

15
sexually assault, batter and sexually abuse Plaintiff, and engage Plaintiff in

Regan’s sex acts. Defendants had a duty to report this improper conduct to school

authorities and to prevent the occurrences thereof, but have failed and refused to

do so.

0. On or about 4/29/19 during the school day, Defendant Regan sexually

assaulted Plaintiff in his office by physically, deliberately, approaching Plaintiff,

looming over Plaintiff, and reaching out for Plaintiff with his hands in order to

sexually abuse Plaintiff, causing in Plaintiff fear, intimidation, anxiety,

apprehension of harm, immobility, loss of freedom, enervation, emotional distress

and suffering.

p. On or about 4/29/19 during the school day, Defendant Regan sexually

battered Plaintiff in his office by physically, deliberately grasping Plaintiff by her

neck, pulling Plaintiff by her neck towards him, pressing his body against her,

maneuvering his mouth unto her lips, covering her lips with his mouth, then

shoving his tongue into her mouth; with the intention to commit sex acts against

Plaintiff, and thereby intentionally, willfully, committing the first sex acts of those

other sex acts upon Plaintiff he intended. This caused in Plaintiff fear,

intimidation, anxiety, immobility, loss of freedom, enervation,‘ disgust, revulsion,

alarm, terror, dread, emotional distress, panic, trembling, apprehension of harm,

abhorrence, and suffering.

q. On or about 4/29/19 during the school day and after Regan sexually

battered Plaintiff, Defendant Regan improperly text-messaged Plaintiff wherein

Regan explored and enquired whether Plaintiff enjoyed and accepted this assault

l6
and battery upon Plaintiff by Regan. This text message was intended by

Defendant Regan to intimidate, frighten, cajole and entrap Plaintiff into i) ex post

facto consent to and approval of the aforesaid the sexual abuse, assault and battery

of Plaintiff by Regan ii) submitting to further sexual abuse, assault and battery by

Regan; and Plaintiff was thereby intimidated, frightened, disgusted, revulsed,

alarmed, terrorized, distressed, caused to suffer apprehension and foreboding that

Regan would exercise his power and authority as H.S. Principal to do harm to her

if she didn’t comply with his illicit wishes, and caused Plaintiff to panic and to

suffer emotionally and physically.

r. On or about 4/29/19, during the school day and after Regan sexually

battered Plaintiff, in full View of Defendants’ agents and employees, Defendant

Regan caused Plaintiff to enter his office in order to compel, cajole and overreach

Plaintiff to cooperate with Regan to cover up Regan’s illicit acts and texts and

photos, and destroy evidence of Regan’s illicit acts and texts and photos, and to

intimidate, frighten, cajole and overreach Plaintiff into consent and approval of

the sexual abuse, assault and battery of Plaintiff by Regan, and into destroying the

text messages and photo evidence of Regan’s aforesaid illicit behaviors by

deleting said texts and photos from Plaintiffs cell phone, and by lying to any

authority, including but not limited to Plaintiff’s parents, to conceal Regan’s illicit

behaviors.

s. On or about 4/29/19 during the school day, in Defendant Regan’s office,

Regan compelled, cajoled, and overreached Plaintiff to engage in covering up

Regan’s illicit acts and texts and photos, and destroy evidence of Regan’s acts,

l7
texts and photos. At his direction and with his assistance, Plaintiff deleted texts

and photos from her cell phone, and under Regan’s aforesaid urging, direction,

and pressure, agreed to lie to authorities to conceal Regan’s illicit behaviors.

These acts by Regan were intended to and did cause Plaintiff to be frightened,

alarmed, terrorized, distressed, to suffer foreboding and apprehension, panic,

emotional and physical distress.

t. Defendant Regan caused Plaintiff to fear Defendant Regan and to be

intimidated by Regan, and to feel isolated and vulnerable to Regan, and to be

separated from Plaintiff’s friends, by walking Plaintiff from the high school to her

vehicle almost daily when the school day ended, in full view of students, teachers

and administrators, from January 2019 through April 29, 2019.

70. At all times herein, Defendants had a duty to protect Plaintiff as a student in

Defendants’ high school from all of the aforesaid illicit behaviors by Defendant Regan,

and Defendants failed, neglected, and refused to do so.

71. At all times herein Defendants were responsible for and liable for the acts of their

agents and employees including Defendant Regan, in the course of their employment.

AS FOR A FIRST CAUSE OF ACTION:


SEXUAL ASSAULT

72. By reason of the foregoing, Defendant Regan sexually assaulted Plaintiff.

73. By reason of the foregoing, Defendants are liable for the sexual assault upon

Plaintiff, in that at all times herein Defendants were responsible for and liable for the acts

18
of their agents and employees including Defendant Regan, in the course of their

employment.

74. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

AS FOR A SECOND CAUSE OF ACTION:


SEXUAL BATTERY

75. By reason of the foregoing, Defendant Regan sexually battered Plaintiff.

76. By reason of the foregoing, Defendants are liable for the sexual battery against

Plaintiff, in that at all times herein Defendants were responsible for and liable for the acts

of their agents and employees including Defendant Regan, in the course of their

employment.

77. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

AS FOR A THIRD CAUSE OF ACTION:


SEXUAL ABUSE

78. By reason of the foregoing, Defendant Regan sexually abused Plaintiff.

l9
79. By reason of the foregoing, Defendants are liable for sexual abuse of Plaintiff in

that at all times herein Defendants were responsible for and liable for the acts of their

agents and employees including Defendant Regan, in the course of their employment.

80. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

AS FOR A FOURTH CAUSE OF ACTION:


SEXUAL HARASSMENT

81. By reason of the foregoing, Defendant Regan sexually harassed Plaintiff.

82. By reason of the foregoing, Defendants are liable for sexual harassment of

Plaintiff, in that at all times herein Defendants were responsible for and liable for the acts

of their agents and employees including Defendant Regan, in the course of their

employment.

83. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical emotional damage, invasion of her privacy, humiliation, degradation and


and
loss of dignity, all to her damages in a sum to be determined by the trier of fact.

20
AS FOR A FIFTH CAUSE OF ACTION:
VIOLATION OF TITLE IX, 20 USC§1681 et seq.

84. Plaintiff repeats paragraphs 1 -

75 herein.

85. At all times each of Defendants had the authority, individually and collectively, to

institute corrective measures on behalf of Defendant District to interfere with, cause

cessation of, impede, and otherwise prevent or thwart a) Defendant Regan’s illicit sexual

grooming techniques used upon Plaintiff and other students; b) Defendant Regan’s

aforesaid threatening behaviors; 0) Defendant Regan’s improper aforesaid relationship

imposed upon Plaintiff; d) Defendant’s sexual harassment of Plaintiff, sexual abuse of

Plaintiff, sexual assault upon Plaintiff, sexual battery of Plaintiff; e) Defendant’s willful

aforesaid conduct in using Plaintiff as his agent in causing Plaintiff to erase electronic

information on Plaintiff’s cellphone in order to conceal his aforesaid unlawful conduct.

86. Each of Defendants at all times herein failed and refused to exercise their

individual and/or collective authority to interfere with, cause cessation of, impede and

otherwise prevent or thwart Defendant Regan’s aforesaid unlawful behaviors, and to

protect Plaintiff and her welfare, and that of other students.

87. Each of Defendants at all times herein exercised and demonstrated deliberate

indifference and reckless indifference: a) to each of Defendant Regan’s aforesaid

unlawful acts and behaviors; b) as to Plaintiff’s welfare and that of other students in the

Defendant District.

88. Each of Defendants had an individual and/or collective obligation to have

supervised and monitored H.S Principal Regan in his relationship with Plaintiff and with

other students.

21
89. Defendant District at all times, is and was a public school district receiving

various federal funds, subject to 20 USC§1681 et seq.

90. Upon information and belief, at all times herein, it was a policy, custom or

practice of Defendants individually and collectively to exercise and demonstrate

deliberate indifference and reckless indifference as to the behaviors of administrators,

including Defendant Regan a) in relation to students including Plaintiff and b) as to the

personal relationships of administrators, including Defendant Regan, with students,

including Plaintiff.

91. By reason of the foregoing, Defendant Regan, being free from Defendants’

individual and collective scrutiny and supervision, and from exercise of Defendants’

individual and collective authority as aforesaid, was enabled to engage in and maintain

for a substantial time, the aforesaid unlawful conducts and relationships with Plaintiff and

other students, with impunity.

92. By reason of the foregoing, Defendants’ breaches of their aforesaid duties and

obligations caused the aforesaid harms to Plaintiff insofar as sexual predator, harasser,

assaulter, batterer, sexual groomer, Regan had unfettered access to Plaintiff, to the illicit

relationship with Plaintiff, and to carry out, and did carry out all the aforesaid unlawful

and atrocious behaviors as to Plaintiff.

93. By reason of the foregoing, Defendants are liable for violations of Title IX,

ZOUSC Section 1681, et seq, as to the sexual harassment, sexual assault, sexual battery,

and sexual abuse of Plaintiff, in that at all times herein Defendants were responsible for

and liable for the acts of their agents and employees including Defendant Regan, in the

course of their employment.

22
AS FOR A SIXTH CAUSE OF ACTION:
CIVIL RIGHTS VIOLATION OF 42 USC §1983

94. Plaintiff repeats 1 —' 83 herein.


paragraphs

95. At all times, Defendants individually and collectively as state actors, had the

authority and positive duty to protect students, including Plaintiff, in their rights,

privileges and immunities as to their lives, liberties and properties, from all harm,

including harm inflicted by Defendant Regan and by the deliberate indifference and

reckless indifference exercised by Defendants themselves, as aforesaid.

96. At all times, Defendants individually and collectively, including Defendant Regan

in his capacity as H.S. Principal, unlawfully deprived Plaintiff of her right to liberty and

to privacy, and including her right to her welfare, dignity and bodily integrity and as to

her electronic property, and as to a free and appropriate public school education, free of

sexual harassment, abuse, assault, and battery.

97. At all times, plaintiffs aforesaid rights were violated in that Plaintiff was

repeatedly deprived of her liberty and property by Defendants in Defendant Regan’s

office as aforesaid, and deprived of her liberty in being required by Defendant Regan to

be present in and out of school with him, and to devote herself to engaging in numerous

texts communications from Defendant Regan, and being caused by Defendants to erase

electronic information and Videos and photos from her cellphone, and by being subjected

to Defendant Regan’s aforesaid sexual grooming, sexual harassment, sexual abuse,

sexual assault and sexual battery, and engage in the improper unlawful erasure and

destruction of Plaintiff’s electronic property and evidence.

23
98. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered deprivation of property, intimidation, apprehension, foreboding of


harm, panic, depression, physical and emotional damage, invasion of her privacy,

humiliation, degradation and loss of dignity, all to her damages in a sum to be determined

by the trier of fact.

AS FOR A SEVENTH CAUSE OF ACTION:


INTENTIONAL INFLICTION OF EXTREME EMOTIONAL DISTRESS

99. By reason of the foregoing, in his capacity as H.S. Principal, including but not

limited to Defendant Regan’s persistently atrocious sexual texting, depriving Plaintiff of

the school’s proper counseling, isolating Plaintiff, sending perverse photos and videos to

Plaintiff, threatening Plaintiff and those persons associated with Plaintiff, posturing that

Defendant Regan would physically eliminate his infant daughter, removing Plaintiff’s

sister from Plaintiff by causing Plaintiff’ s sister to attend school in Sagamore, persistently

causing Plaintiff to enter and remain in Defendants’ Principal’s office while the windows

of the doors therein were shielded from scrutiny, in order to carry out Defendant Regan’s

perverse purposes, co-opting Plaintiffs time day and night during school hours and non—

school hours, encouraging Plaintiff to masturbate and engage in perverse sex and View

pornography, then sexually abusing, assaulting and battering Plaintiff in his office, and

then using Plaintiff to assist him in covering up and lying about his aforesaid behaviors

and destroying evidence thereof, Defendant Regan engaged in intentional infliction upon

Plaintiff of extreme emotional distress.

24
100. By reason of the foregoing, Defendants are liable for the intentional infliction

upon Plaintiff of extreme emotional distress in that at all times herein Defendants were

responsible for and liable for the acts of their agents and employees including Defendant

Regan, in the course of their employment.

101. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

AS FOR AN EIGHTH CAUSE OF ACTION:


PRIZWA FACIE TORT

102. By reason of the foregoing, in his capacity as H.S. Principal, including but not

limited to Defendant Regan’s persistently atrocious sexual texting, depriving Plaintiff of

the school’s proper counseling, isolating Plaintiff, sending perverse photos and videos to

Plaintiff, threatening Plaintiff and those persons associated with Plaintiff, posturing that

Defendant Regan would physically eliminate his infant daughter, removing Plaintiff’s

sister from Plaintiff by causing Plaintiff’s sister to attend school in Sagamore, persistently

causing Plaintiff to enter and remain in Defendants’ Principal’s office while the windows

of the doors therein were shielded from scrutiny, in order to carry out Defendant Regan’s

perverse purposes, co—opting Plaintiff’s time day and night during school hours and non-

school hours, encouraging Plaintiff to masturbate and engage in perverse sex and View

pornography, then sexually abusing, assaulting and battering Plaintiff in his office, and

then using Plaintiff to assist him in covering up and lying about his aforesaid behaviors

25
and destroying evidence thereof, Defendant Regan engaged in prima facie tort against

Plaintiff.

103. By reason of the foregoing, Defendants are liable for engaging in a prima facie

tort against Plaintiff in that at all times herein Defendants were responsible for and liable

for the acts of their agents and employees including Defendant Regan, in the course of

their employment.

104. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

AS FOR A NINTH CAUSE OF ACTION:


BREACH OF FIDUCIARY DUTIES

105. At all times herein, Defendants stood in loco parentis to Plaintiff, a student in

Defendants’ high school. Thereby, Defendants were fiduciaries of Plaintiff.

106. At all times herein, Defendants were fiduciaries in fact and by law of Plaintiff as

to the proper education of Plaintiff, the physical and mental protection of Plaintiff from

harm, the physical and mental well~being and health of Plaintiff, and the inculcation of

moral, intellectual, ethical principles and good citizenship of Plaintiff.

107. By reason of the foregoing, Defendants enabled Regan, and neglected to prevent

Defendant Regan from, engaging against Plaintiff in the foregoing behaviors.

108. By reason of the foregoing, in his capacity as H.S. Principal, including but not

limited to Defendant Regan’s persistently atrocious sexual texting, depriving Plaintiff of

26
the school’s proper counseling, isolating Plaintiff, sending perverse photos and videos to

Plaintiff, threatening Plaintiff and those persons associated with Plaintiff, posturing that

Defendant Regan would physically eliminate his infant daughter, removing Plaintiff’s

sister from Plaintiff by causing Plaintiff’s sister to attend school in Sagamore, persistently

causing Plaintiff to enter and remain in Defendants’ Principal’s office while the windows

of the doors therein were shielded from scrutiny, in order to carry out Defendant Regan’s

perverse purposes, co—opting Plaintiffs time day and night during school hours and non-

school hours, encouraging Plaintiff to masturbate and engage in perverse sex and View

pornography, then sexually abusing, assaulting and battering Plaintiff in his office, and

then using Plaintiff to assist him in covering up and lying about his aforesaid behaviors

and destroying evidence thereof, Defendants breached their fiduciary duties as to

Plaintiff.

109. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

AS FOR A TENTH CAUSE OF ACTION:


COUNSELING AND PSYCHOLOGICAL MALFEASANCE

110. At all times herein, Plaintiff was in dire need of professional counseling and

psychologist treatment as to Plaintiff’s mental state of depression, and Plaintiffs misuse

of and dependence upon marijuana and alcohol.

27
111. At all times herein, Defendants, their agents and employees knew and should have

known of Plaintiffs aforesaid dire need for professional counseling and psychological

treatment.

112. Accordingly, in or about January 2019 through April 2019, Defendants, their

agents and employees positively undertook to provide such professional counseling and

psychological counseling of Plaintiff by providing Plaintiff with a professional counselor,

and providing Plaintiff in January 2019 with the counseling and psychological service of

HS. Principal, Defendant Regan.

113. At no time did Defendant Regan possess the credentials nor training to provide

professional counseling nor psychological services to Plaintiff.

114. At no time was Defendant Regan qualified to provide professional counseling nor

psychological services to Plaintiff.

115. In and after January 2019, Defendants irrationally, wrongly, and arbitrarily and

capriciously withdrew and/or allowed to lapse, the professional counseling Defendants

had provided to Plaintiff, and instead allowed Defendant Regan at Regan’s urging to

solely continue to provide counseling and psychological services to Plaintiff.

116. Defendants’ professional counseling and psychological services to Plaintiff via

Defendant Regan exclusively consisted of Regan’s sexual grooming of Plaintiff for

Regan’s sexual perverse purposes, in his capacity as H.S. Principal, including but not

limited to Defendant Regan’s persistently atrocious sexual texting, depriving Plaintiff of

the school’s proper counseling, isolating Plaintiff, sending perverse photos and videos to

Plaintiff, threatening Plaintiff and those persons associated with Plaintiff, posturing that

Defendant Regan would physically eliminate his infant daughter, removing Plaintiffs

28
sister from Plaintiff by causing Plaintiff‘s sister to attend school in Sagamore, persistently

causing Plaintiff to enter and remain in Defendants” Principal’s office while the windows

of the doors therein were shielded from scrutiny, in order to carry out Defendant Regan’s

perverse purposes, co-opting Plaintiff s time day and night during school hours and non-

school hours, encouraging Plaintiff to masturbate and engage in perverse sex and view

pornography, then sexually abusing, assaulting and battering Plaintiff in his office, and

then using Plaintiff to assist him in covering up and lying about his aforesaid behaviors.

117. Defendants’ aforesaid provision of such alleged professional services to Plaintiff

was grossly neglectful, deficient, unprofessional and harmful to Plaintiff.

118. By reason of the foregoing, Defendants engaged in counseling and psychological

malfeasance as to Plaintiff, all to Plaintiff’s harm.

119. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

AS FOR AN ELEVENTH CAUSE OF ACTION:


FRAUD

120. Plaintiff repeats allegations in paragraphs 1 —

62 herein.

121. In pretending to professionally counsel and provide psychological services to

Plaintiff, Defendant Regan repeatedly text messaged Plaintiff from January 2019 through

April 29, 2019. Defendant Regan repeatedly fraudulently held out to Plaintiff therein that

his words were intended to professionally counsel and provide psychological services to

29
Plaintiff, whereas the said words were intended to sexually pervert Plaintiff and enable

Defendant Regan to sexually abuse, assault and batter Plaintiff.

122. The texts of Defendant Regan from January 2019 through April 29, 2019

constitute the fraudulent words communicated by Defendant Regan to Plaintiff, attached

as Schedule 1.

123. Plaintiff relied to her detriment upon said fraudulent words in entering into and

continuing the said purported, professional counseling and psychological services

provided by Defendants.

124. By reason of the foregoing, Defendant Regan defrauded Plaintiff.

125. By reason of the foregoing, Defendants defrauded Plaintiff in that at all times

herein Defendants were responsible for and liable for the acts of their agents and

employees including Defendant Regan, in the course of their employment.

126. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

AS FOR A TWELTH CAUSE OF ACTION:


FRAUD IN THE INDUCEMENT

127. Plaintiff repeats allegations in paragraphs 1-62 herein.

128. In or about January 2019 through April 29, 2019, Defendant Regan repeatedly

fraudulently induced Plaintiff to accept Regan as Plaintiff’s only counsellor and to

discontinue other counselors, and implied to Plaintiff in text messages that a) Plaintiff

30
should use, and rely solely upon Defendant Regan’s expertise in providing Plaintiff

professional counselling services and psychological services, when in fact Defendant

Regan had no such expertise and instead intended that Plaintiff be fraudulently induced to

accept his services and rely thereon in order that Defendant Regan could sexually pervert

Plaintiff and enable Regan to sexually abuse, assault, and batter Plaintiff; and b) Plaintiff

should give up the professional counselors provided to Plaintiff and instead rely solely

upon the purported services provided by Regan to Plaintiff, when in fact Regan intended

that Plaintiff be fraudulently induced to accept solely his services and rely solely thereon

in order that Defendant Regan could sexually pervert Plaintiff and enable Regan to

sexually abuse, assault and batter Plaintiff without any scrutiny by or interference by the

other professional counselors provided to Plaintiff.

129. Plaintiff relied to her detriment upon said fraudulent words in entering into and

continuing the said purported, professional counseling and psychological services of

Defendant Regan provided by Defendants.

130. By reason of the foregoing, Defendant Regan fraudulently induced Plaintiff to

rely upon Regan’s aforesaid representations so that Plaintiff would erroneously not use or

rely upon the professional counselors provided to Plaintiff, and would instead rely upon

the control and advices of Regan which were intended to sexually pervert Plaintiff and

enable Regan to sexually abuse, assault and batter Plaintiff.

131. By reason of the foregoing, Defendant fraudulently induced Plaintiff as aforesaid

in that at all times herein Defendants were responsible for and liable for the acts of their

agents and employees including Defendant Regan, in the course of their employment.

31
132. By reason of the forgoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

AS FOR A THIRTEENTH CAUSEOF ACTION:


GROSSLY NEGLIGENT SUPERVISION

133. At all times herein, Defendants had a duty to supervise the actions of Defendants’

agents and employees, including Defendant Regan and those employees who were aware

of or should have been aware of Defendant Regan’s actions and communications

aforesaid, in relation to Plaintiff.

134. Such supervision included but was not limited to a) Regan’s inordinate time spent

in his office with Plaintiff; b) Regan’s behavior in his office with Plaintiff; c) Regan’s

extraordinary time spent texting with Plaintiff; d) Regan’s text messages to and from

Plaintiff; e) Regan’s use of Defendants” cell phone and of Defendants’ landline phone,

and of Regan’s personal phone, the use of which Defendants contributed payment

thereof; f) Regan’s manipulation and alteration of Plaintiffs attendance records, and

performing Plaintiff’ s homework and persuading Plaintiff to submit the said homework

to her teachers as her own; g) Regan’s walking Plaintiff to Plaintiff” 5 vehicle nearly every

day at the end of the school day.

135. Defendants neglected andgrossly neglected to so supervise Defendant Regan and

Defendants’ agents and employees.

32
136. Said neglect and gross neglect by Defendants resulted in the attempted sexual

perversion of Plaintiff by Regan, the sexual abuse of Plaintiff and sexual assault and

battery upon Plaintiff by Regan, and the other aforesaid harms to Plaintiff.

137. By reason thereof, Plaintiff has been damaged by Defendants in that Plaintiff has

suffered intimidation, apprehension, foreboding of harm, panic, depression, physical and

emotional damage, invasion of her privacy, humiliation, degradation and loss of dignity,

all to her damages in a sum to be determined by the trier of fact.

AS FOR A FOURTEENTH CAUSE OF ACTION:


NEGLIGENT HIRING AND RETENTION

138. Upon information and belief, Defendants had at all times since at least 2000, a

duty to hire and retain a principled role model school administrator with proper

credentials, certifications, experience, history and moral and ethical standards and

disposition, and who was not a sexual pervert and sexual predator.

139. Upon information and belief, at all times since 2000, Defendants had a duty of

investigation, inquiry and research as to all applicants when seeking to employ and when

employing and continuing to employ such administrator.

140. Upon information and belief, Defendant Regan was negligently and recklessly

employed as Assistant Principal by Defendants or Defendants’ predecessors, in or about

June 2006.

141. Upon information and belief, Charles Regan was hired on June 26, 2006 as an

“Emergency 20-day Conditional Appointment,” and that at that time of his hiring,

33
Charles Regan’s resume and level of expertise was neither seen by, nor known by, at

least one member on the Board of Education for Riverhead Central School District.

142. Upon information and belief, at least one member of the Board of Education for

Riverhead Central School District was unable and prevented from making a proper, well-

informed decision as to the hiring of Charles Regan.

143. Upon information and belief, Charles Regan’s “Emergency 20-day Conditional

Appointment” was reapproved and extended on at least two separate occasions: the first

extension having been reapproved on July 11, 2006, with an amendment then passing and

made to make Charles Regan’s appointment a Probationary appointment from July 1,

2006 to June 30, 2009; the second extension having been reapproved on July 25, 2006.

144. Defendants knew or should have known that a) Defendant Regan was not

qualified for the aforesaid position; b) there was in fact no such “emergency” which

required that Defendant Regan be hired without proper credentials or vetting; c) the

Defendant District, its agents and employees were knowingly willfully and/or with

reckless disregard for the State’s requirements for “emergency” hiring of an administrator

and for the welfare of the District’s students, misrepresenting to the state and the public

that there was an “emergency” requiring that Regan be so hired.

145. Defendants knowingly, willfully and recklessly hired Defendant Regan

notwithstanding that he was unqualified for employment with the Defendant District,

thereby inserting sexual predator Regan into a position of authority, to wreak sexual

havoc upon Plaintiff.

146. In or about the school year 2013-2014, Defendants negligently, grossly

negligently and recklessly promoted Defendant Regan to employment as High School

34
Principal of Riverhead Central School District, and kept Regan in that position to the

present, when Defendants knew or should have known that Defendant Regan was

unqualified for that position and was a sexual predator, preying upon students including

Plaintiff.

147. From June 2006 to the present, Defendant was negligently retained in

employment as assistant principal and promoted to High School Principal by Defendants

and Defendants’ predecessors.

148. Defendants or Defendants’ predecessors negligently employed Defendant Regan

when Defendants and their predecessors knew and should have known that Defendant

Regan lacked the requisite New York State Certification for the administrative position.

149. Defendants or Defendants’ predecessors engaged in a false and fraudulent

representation in writing to New York State and the public, that there existed an

“emergency” requiring the Defendants or Defendants’ predecessors to employ Defendant

Regan as assistant Principal, in order to enable Defendants or their predecessors to hire

Defendant Regan although Regan lacked proper certification for said position, when in

fact upon information and belief, no such true emergency existed.

150. At all times, upon information and belief, Defendants knew or should have known

that Defendant Regan had been previously accused of engaging in, and did engage in

improper personal and sexual relationships with female students in his previous

employment as a Special Education teacher and girls basketball coach in the South

Manor Schools and Eastport/South Manor Schools and upon information and belief, in

his previous employment with B.O.C.E.S.

35
;

f'u/ pm 1),;

151. Nonetheless, Without engaging in a full, proper investigation, inquiry and research

to Defendant Regan, and without properly taking into


as account Regan’s employment

history, credentials, experience, history, and moral and ethical standards and disposition,

Defendants and their predecessors, recklessly, negligently and grossly negligently

employed and promoted Defendant Regan as aforesaid, and continued him in his

employment to the present.

152. By reason of the said employment, promotion and continuing employment of

Defendant Regan, Defendants enabled sexual predator and sexual pervert Regan to

sexually groom Plaintiff for Regan’s aforesaid sexual depredations and to engage in said

sexual depredations as to Plaintiff, all to Plaintiffs harm and damages as aforesaid.

153. By reason of the foregoing, Defendants are responsible for and liable for the

negligent and grossly negligent employment, promotion and retention of Regan.

154. By reason of the foregoing, Plaintiff has been damaged by Defendants in that

Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,

physical and emotional damage, invasion of her privacy, humiliation, degradation and

loss of dignity, all to her damages in a sum to be determined by the trier of fact.

155. For each and every aforesaid cause of action, Plaintiff is entitled to punitive

damages, attorneys’ fees, costs and disbursement in a sum to be determined by the trier of

fact.

WHEREFORE, Plaintiff prays for judgement as follows:

a) On the first cause of action for Sexual Assault, for damages, punitive damages and

attorneys’ fees, costs, and disbursements, in a sum to be determined by the trier of fact.

36
19) On the second cause of action for Sexual Battery, for damages, punitive damages and

attorneys’ fees, costs, and disbursements, in a sum to be determined by the trier of fact.

On the third cause of action for Sexual Abuse, for damages, punitive damages and

attorneys’ fees, costs and disbursements, in a sum to be determined by the trier of fact.

d) On the fourth cause of action for Sexual Harassment, for damages, punitive damages and

attorneys’ fees, costs and disbursements, in a sum to be determined by the trier of fact.

On the fifth of action for Violation of Title IX, 20USC§1681 for


cause et seq., damages,

punitive damages and attorneys’ fees, costs and disbursements, in a sum to be determined

by the trier of fact.

On the sixth cause of action for Civil Rights Violation of 42USC§1983, for damages,

punitive damages and attorneys’ fees, costs and disbursements, in a sum to be determined

by the trier of fact.

g) On the seventh cause of action for Intentional Infliction of Extreme Emotional Distress,

for damages, punitive damages and attorneys’ fees, costs and disbursements, in a sum to

be determined by the trier of fact.

h) On the eighth cause of action for Prima Facie Tort for damages, punitive damages and

attorneys’ fees, costs and disbursements, in a sum to be determined by the trier of fact.

On the ninth cause of action for Breach of Fiduciary Duties, for damages, punitive

damages and attorneys’ fees, costs and disbursements, in a sum to be determined by the

trier of fact.

j) On the tenth cause of action for Professional Counseling and Psychological Malfeasance,

for damages, punitive damages and attorneys’ fees, costs and disbursements, in a sum to

be determined by the trier of fact.

37
k) On the eleventh cause of action for Fraud, for damages, punitive damages and attorneys’

fees, costs and disbursements, in a sum to be determined by the trier of fact.

1) On the twelfth cause of action for Fraud In the lnducement, for damages, punitive

damages and attorneys’ fees, costs and disbursements, in a sum to be determined by the

trier of fact.

m) On the thirteenth cause of action for Negligent and Grossly Negligent Supervision, for

and attorneys” fees, costs and disbursements, in to be


damages, punitive damages a sum

determined by the trier of fact.

n) On the fourteenth cause of action for Negligent Hiring and Retention, for damages,

punitive damages and attorneys” fees, costs and disbursements, in a sum to be determined

by the trier of fact, and for any other just and proper relief.

Dated: August 5, 2019


Miller Place, New York

Ray, Mmes, LLP


Attorney(s) for Plaintifl
122 North Country Road
P. O. Box 5440
Miller Place, NY 11764
(631) 473-1000
john@raymitevlaw.com

38
VERIFICATION

STATE OF NEW YORK )


) ss.:

COUNTY OF SUFFOLK )

ANASTASIA STAPON, being duly sworn, deposes and says:

She is the Plaintiff in the within action; she has read and knows the contents of the
foregoing Complaint and the same is true to her own knowledge, except as to the matters therein
stated to be alleged upon information and belief, and that as to those matters she believes it to be

/%@:> ANASTASIA STAP

Sworn to before 6 this


5“ day of ,2019

W
Notary Fflbli/é/
V

NOTARY
JOHN RAY ‘1‘.
Pusuc-smfis" OF NEW
No.
{0w
O2RA4786739 I

Q untitled
In Suffolk Co
My unty
Gemmmlon Expires
May 3!.
mafia?»

3‘?
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 1 of 201 PageID #: 297
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 2 of 201 PageID #: 298
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 3 of 201 PageID #: 299
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 4 of 201 PageID #: 300
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 5 of 201 PageID #: 301
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 6 of 201 PageID #: 302
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 7 of 201 PageID #: 303
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 8 of 201 PageID #: 304
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 9 of 201 PageID #: 305
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 10 of 201 PageID #: 306
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 11 of 201 PageID #: 307
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 12 of 201 PageID #: 308
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 13 of 201 PageID #: 309
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 14 of 201 PageID #: 310
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 15 of 201 PageID #: 311
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 16 of 201 PageID #: 312
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 17 of 201 PageID #: 313
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 18 of 201 PageID #: 314
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 19 of 201 PageID #: 315
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 20 of 201 PageID #: 316
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 21 of 201 PageID #: 317
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 22 of 201 PageID #: 318
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 23 of 201 PageID #: 319
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 24 of 201 PageID #: 320
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 25 of 201 PageID #: 321
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 26 of 201 PageID #: 322
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 27 of 201 PageID #: 323
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 28 of 201 PageID #: 324
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 29 of 201 PageID #: 325
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 30 of 201 PageID #: 326
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 31 of 201 PageID #: 327
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 32 of 201 PageID #: 328
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 33 of 201 PageID #: 329
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 34 of 201 PageID #: 330
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 35 of 201 PageID #: 331
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 36 of 201 PageID #: 332
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 37 of 201 PageID #: 333
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 38 of 201 PageID #: 334
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 39 of 201 PageID #: 335
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 40 of 201 PageID #: 336
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 41 of 201 PageID #: 337
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 42 of 201 PageID #: 338
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 43 of 201 PageID #: 339
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 44 of 201 PageID #: 340
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 45 of 201 PageID #: 341
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 46 of 201 PageID #: 342
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 47 of 201 PageID #: 343
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 48 of 201 PageID #: 344
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 49 of 201 PageID #: 345
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 50 of 201 PageID #: 346
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 51 of 201 PageID #: 347
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 52 of 201 PageID #: 348
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 53 of 201 PageID #: 349
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 54 of 201 PageID #: 350
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 55 of 201 PageID #: 351
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 56 of 201 PageID #: 352
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 57 of 201 PageID #: 353
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 58 of 201 PageID #: 354
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 59 of 201 PageID #: 355
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 60 of 201 PageID #: 356
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 61 of 201 PageID #: 357
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 62 of 201 PageID #: 358
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 63 of 201 PageID #: 359
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 64 of 201 PageID #: 360
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 65 of 201 PageID #: 361
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 66 of 201 PageID #: 362
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 67 of 201 PageID #: 363
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 68 of 201 PageID #: 364
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 69 of 201 PageID #: 365
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 70 of 201 PageID #: 366
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 71 of 201 PageID #: 367
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 72 of 201 PageID #: 368
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 73 of 201 PageID #: 369
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 74 of 201 PageID #: 370
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 75 of 201 PageID #: 371
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 76 of 201 PageID #: 372
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 77 of 201 PageID #: 373
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 78 of 201 PageID #: 374
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 79 of 201 PageID #: 375
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 80 of 201 PageID #: 376
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 81 of 201 PageID #: 377
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 82 of 201 PageID #: 378
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 83 of 201 PageID #: 379
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 84 of 201 PageID #: 380
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 85 of 201 PageID #: 381
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 86 of 201 PageID #: 382
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 87 of 201 PageID #: 383
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 88 of 201 PageID #: 384
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 89 of 201 PageID #: 385
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 90 of 201 PageID #: 386
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 91 of 201 PageID #: 387
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 92 of 201 PageID #: 388
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 93 of 201 PageID #: 389
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 94 of 201 PageID #: 390
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 95 of 201 PageID #: 391
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 96 of 201 PageID #: 392
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 97 of 201 PageID #: 393
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 98 of 201 PageID #: 394
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 99 of 201 PageID #: 395
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 100 of 201 PageID #: 396
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 101 of 201 PageID #: 397
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 102 of 201 PageID #: 398
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 103 of 201 PageID #: 399
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 104 of 201 PageID #: 400
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 105 of 201 PageID #: 401
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 106 of 201 PageID #: 402
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 107 of 201 PageID #: 403
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 108 of 201 PageID #: 404
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 109 of 201 PageID #: 405
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 110 of 201 PageID #: 406
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 111 of 201 PageID #: 407
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 112 of 201 PageID #: 408
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 113 of 201 PageID #: 409
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 114 of 201 PageID #: 410
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 115 of 201 PageID #: 411
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 116 of 201 PageID #: 412
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 117 of 201 PageID #: 413
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 118 of 201 PageID #: 414
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 119 of 201 PageID #: 415
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 120 of 201 PageID #: 416
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 121 of 201 PageID #: 417
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 122 of 201 PageID #: 418
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 123 of 201 PageID #: 419
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 124 of 201 PageID #: 420
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 125 of 201 PageID #: 421
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 126 of 201 PageID #: 422
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 127 of 201 PageID #: 423
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 128 of 201 PageID #: 424
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 129 of 201 PageID #: 425
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 130 of 201 PageID #: 426
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 131 of 201 PageID #: 427
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 132 of 201 PageID #: 428
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 133 of 201 PageID #: 429
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 134 of 201 PageID #: 430
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 135 of 201 PageID #: 431
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 136 of 201 PageID #: 432
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 137 of 201 PageID #: 433
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 138 of 201 PageID #: 434
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 139 of 201 PageID #: 435
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 140 of 201 PageID #: 436
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 141 of 201 PageID #: 437
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 142 of 201 PageID #: 438
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 143 of 201 PageID #: 439
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 144 of 201 PageID #: 440
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 145 of 201 PageID #: 441
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 146 of 201 PageID #: 442
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 147 of 201 PageID #: 443
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 148 of 201 PageID #: 444
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 149 of 201 PageID #: 445
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 150 of 201 PageID #: 446
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 151 of 201 PageID #: 447
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 152 of 201 PageID #: 448
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 153 of 201 PageID #: 449
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 154 of 201 PageID #: 450
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 155 of 201 PageID #: 451
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 156 of 201 PageID #: 452
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 157 of 201 PageID #: 453
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 158 of 201 PageID #: 454
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 159 of 201 PageID #: 455
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 160 of 201 PageID #: 456
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 161 of 201 PageID #: 457
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 162 of 201 PageID #: 458
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 163 of 201 PageID #: 459
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 164 of 201 PageID #: 460
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 165 of 201 PageID #: 461
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 166 of 201 PageID #: 462
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 167 of 201 PageID #: 463
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 168 of 201 PageID #: 464
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 169 of 201 PageID #: 465
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 170 of 201 PageID #: 466
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 171 of 201 PageID #: 467
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 172 of 201 PageID #: 468
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 173 of 201 PageID #: 469
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 174 of 201 PageID #: 470
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 175 of 201 PageID #: 471
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 176 of 201 PageID #: 472
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 177 of 201 PageID #: 473
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 178 of 201 PageID #: 474
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 179 of 201 PageID #: 475
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 180 of 201 PageID #: 476
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 181 of 201 PageID #: 477
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 182 of 201 PageID #: 478
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 183 of 201 PageID #: 479
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 184 of 201 PageID #: 480
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 185 of 201 PageID #: 481
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 186 of 201 PageID #: 482
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 187 of 201 PageID #: 483
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 188 of 201 PageID #: 484
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 189 of 201 PageID #: 485
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 190 of 201 PageID #: 486
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 191 of 201 PageID #: 487
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 192 of 201 PageID #: 488
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 193 of 201 PageID #: 489
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 194 of 201 PageID #: 490
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 195 of 201 PageID #: 491
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 196 of 201 PageID #: 492
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 197 of 201 PageID #: 493
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 198 of 201 PageID #: 494
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 199 of 201 PageID #: 495
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 200 of 201 PageID #: 496
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 201 of 201 PageID #: 497
Case 2:19-cv-04708-WFK-ST Document 1-4 Filed 08/15/19 Page 1 of 5 PageID #: 498
Case 2:19-cv-04708-WFK-ST Document 1-4 Filed 08/15/19 Page 2 of 5 PageID #: 499
Case 2:19-cv-04708-WFK-ST Document 1-4 Filed 08/15/19 Page 3 of 5 PageID #: 500
Case 2:19-cv-04708-WFK-ST Document 1-4 Filed 08/15/19 Page 4 of 5 PageID #: 501
Case 2:19-cv-04708-WFK-ST Document 1-4 Filed 08/15/19 Page 5 of 5 PageID #: 502