RECEIVED way 1.6 208 Eastport-South Manor CSD Diet Clerk Claimant, against. CHARLES REGAN, EASTPORT-SOUTH MANOR CENTRAL SCHOOL DISTRICT, and superintendents, administrators, principals and ‘their employees and/or agents, from 1997 through 2002, Respondents PLEASE TAKE NOTICE that Clint, INN by her attorneys ay, Mite & ‘Associates, LLP, hereby sates a claim and presents tis Notice of Clam aginst te Respondents and alleges a follows: 1 The name and adicess of the Clement: i | 2 Respondents (collectively refered to as “Respondent”) are the Extport-South Manor Central Schoo! District, its agents and employees, incluting but not nite to, all sopeintendents, administrators, prisepals and their employes andor agents, from 1997 through 2002, and Charles Regan, former teacher and coach at Baetport South Manor Carel School Dist 3. The times, dates and places where the claims arose were: fiom I2am. to 11:59 pm, from day to day, fom approximately September 1997 Wwough Jane 200, nd damages continue tothe present, Eastport South Menor Cental School Disc caster Suk Cony, and in South Manor public schools and in Eastport public schools during the afr tines aad ‘ates, During the relevant school dates, that, ftom September 1997 to June 1999 vas 13,years old through 15 years old, at Dayton Avenve Schoo. Ske was a basketball eam player Soh nr Speci! Education ache Caris Regn ean herbs nah at Don Avenue School, Dung the aforesaid time and dates, Regan willfily, actively pursued te grooming of AD ict sexual purposes. He was fequently with rin and ou of sch sliced her sttetion, grossly overeached her, befiended her, counseled hes, bee her met, ook her and other female students to the beach, to watch him surf end beguile them, fe we sexe Jnmiendos frequently wit her and other young female student, amongst other soul grooming 1ethods, These grooming behaviors were notorious, and upon information and tee, observed by seool employees, administrators, students an sevesl pects, Nothing was done by any Respondent to prevent this gross misbehavior by Regan. The Respondent taiy aod opealy cocourage this sre sisbebavor. 4. When care « high-school studentt Eastport schools in 1999-2002) Regan increased he afresid rooming of ond other stent in sine en inntensiy 5. When vas 16 years old, Regen compelld ecto purshase tees tou Kriets ‘game in New York City for himself and her He told er todo this so that thy cule ogee, but also so that noone ese would know ofthis, Regan reimbursed her fr the purine. 6. Regan purchased alcoholic bevereges er atthe Knicks gametiey tended together, in ar about 2000. Hedi o in order to weaken he resistance to his advances an reader ber defenseless 7. After the Kicks game, Regan took Mio the basement of his paras" house in ‘Manor, There, when she was inbrsted under hs tutelage, he desinded of i importuned her to give him oral sex, which she did at his behest. He did so without protectin from STDs, codanging8 IMI otter went one search fr ND seo cid notre home tom ‘he Knicks game, and then ported her absence (she was gone vay from home wits Regan wi ‘pproximatey 3:00 am) andthe Knicks" game atendance othe Bsstport School uninstation, 9. The Respondents administrators ofboth South Manor public schoolsand Eastport, ‘bli schools conducted a perfunctory, fille, careless investigation of the Knicks game noounter end ene affir beeen QUIN and Regan. Regan led to the Respondats fdminisrators about the event He demended of QJM thst sve lie about its well tothe aciminisators, which she di. Seid eéminstators did nothing to pereptively exnine QP regarding her fale story, instead inationally, grossly neglectilly and willy credited the improbable story at fae value, Seid administrator did nothing of substance of vat verify the ‘veracity AQMD or Regan’s false stores. Regan sc sold the adminisntors that she was at fiend’ party where her driver beeame dunk, so she called Regan otk hr hame which he did. Al this was false, nd transparently so. QM mother expressed to the Respondent her Abele of the false story. Respondent knew and should have known tht the enounter was Impropee. Respondent di nothing mare. 10, GUM rote thereat dtivered to Respondent electronic sel messges ‘bemeen Regan and QUEM which were intimate. Respondent did nothing abit this. Bach Respondent was a mandated epoter of child shure, yet none made any such ep. 11, Regan continued the iit relationship with QJ Jn at east hee occasions, hil QUID wes a 17-yearold stadt in Responds’ schools, Regan demande ard cjled nave sexu intercourse with Regan, Sena intercourse oocure on eachocasion, 12, GMM severy metly end pryholgially damaged by ena te above