STATE OF NEW YORK COURT OF CLAIMS COUNTY OF MONROE JOSEPH MUNNO, ‘Claimant, NOTICE OF INTENTION TO FILE CLAIM -against- INDEX NO. CITY OF ROCHESTER, MAYOR LOVELY WARREN, individually and as Mayor of the City of Rochester, THE UNIVERSITY PREPARATORY CHARTER SCHOOL FOR YOUNG MEN, STATE UNIVERSITY OF NEW YORK SYSTEM, Defendants. TO: CITY OF ROCHESTER ‘THE UNIVERSITY PREPARATORY CHARTER SCHOOL FORYOUNG MEN: PLEASE TAKE NOTICE, that JOSEPH MUNNO hereby makes claim against the CITY OF ROCHESTER, MAYOR LOVELY WARREN, both individually and in her capacity of Mayor of the City of Rochester, and THE UNIVERSITY PREPARATORY CHARTER SCHOOL FOR YOUNG MEN, STATE UNIVERSITY OF NEW YORK SYSTEM, for damages arising from libelous and slanderous conduct on the part of its employees, elected officials, trustees, board of trustees, resulting in damage to his reputation in the community as an esteemed educator, resulting in personal injuries, medical expenses, breach of his rights of employment, and damages generally sustained by him on account of the said defamation thereof, the claimant states: 1. The post office address for the claimant herein is: Joseph Munno 3 Dominic WayRochester, New York 14612 2. The Attorneys for the Claimant herein are: LAW OFFICES OF PAUL GUERRIERI, Paul GUERRIERI, Esq., of counsel One East Main Street Rochester, New York 14614 Phone: (585) 672-4823 3. The time when and the place where such claim arose and the nature of the same are as follows: 4, The Claim of JOSEPH MUNNO, (hereafter, “Claimant”), is for damages arising from conduct of THE CITY OF ROCHESTER (hereafter, the “City”), the Mayor of the City of Rochester, LOVELY WARREN, individually and as an official of the City of Rochester, (hereinafter, “Warren” or “Mayor”), THE UNIVERSITY PREPARATORY CHARTER SCHOOL FOR YOUNG MEN, (hereafter, “UPREP"), and STATE UNIVERSITY OF NEW YORK SYSTEM (hereafter, “SUNY”) for conduct committed by their agents, servants or employees constituting defamation of Claimant's character and fine reputation in this community through libelous and slanderous statements and false inuendo resulting in permanent damage to his reputation as an educator 5. The slanderous conduct includes but is not limited to a media event which occurred on or about July 2, 2018 at the Rochester City Hall in the Mayor's Chambers where the mayor gave a 2 % minute speech falsely accusing Claimant of denying a student the honor of giving a valedictorian speech at the 2018 UPREP graduation ceremony. Additionally, the City or Rochester, by their agents, servants or employees, including the Mayor, was published on the City of Rochester website and/or the City of Rochester’s official YouTube Channel, and the Mayor's official Facebook page, and remains public to this day on the YouTube and other social media outlets. Upon -2-information and belief, the media event was designed and organized to gain national and international coverage, and the lies and innuendo were spread throughout the local community, nationally and internationally. 6. Additionally, July 9, 2018, the Mayor stated the valedictorian was denied his valedictorian speech, and claimed she called the principal but did not hear back, and stated Claimant denied the valedictorian’s right to speak at commencement, which is completely contrary to the facts of this case. UPREP board members noted disappointment and resulting negative attention distracted from the significant accomplishments of the school during its eight years of operation after Mayor Warren's speech which resulted in national headlines reading, ‘Principal Refuses to Allow First Black Valedictorian To Give Speech, So Rochester Mayor —Intervenes’ (CBSNEWS.COM). 7. Thereafter, the Mayor continued disparagement towards Claimant during news interviews with local media and newspapers. 8. The accident occurred on July 2, 2018 at Rochester City Hall, 30 Church Street, Rochester, New York. 9. Claimant believes that because of the media spectacle created by the Mayor and the City, Claimant was wrongfully terminated from his position as president of UPREP. 10. UPREP, its board members, trustees, and graduating committee, all were fully aware of the true facts and circumstances surrounding that led to the valedictorian not speaking at the 2017 commencement ceremony. All knew the valedictorian was not prohibited from speaking and that it was his decision and desire to decline that honor.