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CSA Files a Notice of Claim Against the City of New York and the NYC Department of Education

September 23, 2004

Remedy: $10 million per Plaintiff, for each of the 45 Principals named in the media as being removed by Joel Klein.

Contact:

Richard Relkin Brian Gibbons
Director of Public Relations, CSA Asst. Dir. Public Relations
718-852-3000 ext.211 718-852-3000 ext. 273
646-261-9543 mobile 914-484-0224 mobile
Richard@csa-nyc.org Brian@csa-nyc.org
www.csa-nyc.org

CSA FILES NOTICE OF CLAIM AGAINST DOE ON BEHALF OF 'REMOVED' PRINCIPALS
PRINCIPALS SUFFER DAMAGES TO REPUTATION; LOSS OF EARNINGS

On Thursday September 23rd, the Council of School Supervisors and Administrators (CSA) filed a Notice of Claim on behalf of 30 Principals who on June 28th, 2004 the Department of Education placed on a publicly released list of allegedly unsatisfactory Principals. The lawsuit will claim breach of contract, defamation as well as negligent and intentional torts.

"Joel Klein broke the law when he released this list," said CSA President Jill Levy. "He must be held accountable and responsible for his actions, just like every other person who works for the Department of Education."

The plaintiffs' names were on a list of allegedly unsatisfactory Principals released to various media outlets by Chancellor Klein. CSA claims the list contained numerous and substantial misrepresentations.

The plaintiffs are claiming damages to reputation; loss of earnings as well as the ability to secure future employment.

Notice of Claim:

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

---------------------------------------------------------------------X

In the Matter of the Claim of (NAMES REDACTED BY CSA).


- against -


The City of New York, the Department of Education of the
City of New York, Joel Klein as Chancellor of the New York
City Department of Education of the City of New York, and John/
Jane Doe(s) #1-3 as individuals employed by the New York
City Department of Education of the City of New York and/or
The City of New York.

---------------------------------------------------------------------X
TO: Michael Cardozo, Corporation Counsel of the City of New York
William Thompson, Comptroller of the City of New York

PLEASE TAKE NOTICE that the claimants herein hereby make claim and demand against The City of New York, the Department of Education of the City of New York, Joel Klein as
Chancellor of the Department of Education of the City of New York, and John/Jane Doe(s)
as individuals employed by the New York City Department of Education of the City of New York and/or the City of New York as follows: That claimants were defamed by Joel Klein as Chancellor of the Department of Education of the City of New York, were the subjects of breach of contract by the City of New York, were the subjects of breach of numerous Stipulations of Settlement and public disclosure of such Stipulations of Settlement by Joel Klein as Chancellor of the Department of Education of the City of New York.

1. The names and post office address of claimants and their attorneys are:

Claimants:

(NAMES AND ADDRESSES REDACTED BY CSA)

Attorneys for claimants: Bruce K. Bryant, Barbara A. Jaccoma, David N. Grandwetter
Council of School Supervisors and Administrators
16 Court Street, 4th Floor
Brooklyn, New York 11241
(718) 852-3000


2. The nature of the claim is breach of contract, defamation, negligent and intentional torts, and abuse of discretion; plaintiffs are current or former employees who worked as school Principals in the Department of Education of the City of New York for school years including, but not limited to, the 2003-2004 school year; Plaintiffs were the subjects of defamatory acts, contractual breach, Stipulation of Settlement breaches, and public disclosure of the same by Joel Klein as Chancellor of the Department of Education of the City of New York; plaintiffs were the subjects on a list of 45 allegedly unsatisfactory Principals released by Chancellor Klein to various media outlets on June 28, 2004 after Chancellor Klein invited these media outlets to submit a Freedom of Information Law request for the list of 45 names. The list released contained numerous and substantial misrepresentations relating to claimants.

3. The time when, the place where, and the manner in which the claim arose: Claimant's names were publicized to various media outlets by Chancellor Klein on June 28, 2004 from the Department of Education's headquarters at Tweed Courthouse, 52 Chambers Street in New York, New York 10007.

4. The items of damage or injuries claimed are: damages to reputation; loss of earnings; emotional distress; damages to Plaintiff's ability to secure future employment; impairment of earning power. The items of damage or injuries claimed amount to $10 million per plaintiff.

The claim and demand is hereby presented for adjustment and payment.

PLEASE TAKE FURTHER NOTICE that by reason of the foregoing, in default of the City of New York to pay the claimant his/her claim within the time limited for compliance with this demand by the City of New York by the City of New York by the applicable statutes, claimant intends to commence an action against the City of New York to recover his/her damages with interests and costs.



Dated: Brooklyn, New York __________________
September 22, 2004 Bruce K. Bryant


_____________________
Barbara A. Jaccoma

_____________________
David N. Grandwetter


Sworn to before me this ____ day
of September, 2004

________________________________
Notary Public