SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK LISA STEGLICH, individually and as parent and natural guardian : of ALEXANDER HERLIHY, infant, RIC CHERWIN, individually and as parent and natural guardian of MARLEY Index No, 104300/11 CHERWIN, infant, CAROL BARKER, individually and as parent and natural guardian of OMARI BROWN, infant, GINA IAS Part 29 DEMETRIUS, individually and as parent and natural guardian of (Torres, J.) SEBASTIAN DEMETRIUS, KIMBERLY JARNOT, individually : and as parent and natural guardian of MARGARET THOMAS, AFFIDAVIT OF infant, NYDIA JORDAN, individually and as parent and natural: LISA STEGLIGH guardian of HARRY D. JORDAN, infant, KAVERY KAUL, individually and as parent and natural guardian of ASHOK KAUL, infant, RUBEN and GERALDINE LOPEZ, individually and as parents and natural guardians of SHANE LOPEZ, infant, MADELINE OLMEDA, individually and as parent and natural guardian of CRISTINA JULLIA CRUZ, infant, LAZARA QUINONES, individually and as parent and natural guardian of DORIS ALCANTARA, infant, and MARILYNN SARJEANT, individually and as parent and natural guardian of ALIYA CLUNIE, infant, Petitioners, -against- THE BOARD OF EDUCATION OF THE CITY SCHOOL DISTRICT OF THE CITY OF NEW YORK a/k/a THE PANEL FOR EDUCATIONAL POLICY, THE DEPARTMENT OF EDUCATION OF THE CITY OF NEW YORK, and DENNIS M. : WALCOTT, as Chancellor-Designate of the City School District of the City of New York, Respondents, STATE OF NEW YORK) 28S. COUNTY OF NEW YORK. ) LISA STEGLICH, being duly swom, deposes and says: 1 1am a Petitioner in this action and the President of the Parent-Teacher of Frank McCourt High School (“Frank McCourt”), one of the five high schools 11438191currently occupying and utilizing the Brandeis Educational Campus (“Brandeis Campus”) located in Community School District 3. 2. ‘The October 6, 2010 emails attached as Exhibits A-E of the Affidavit of Paymon Rouhanifard (the “Rouhanifard Aff.”), which purport to request feedback concerning the Brandeis under-utilization designation, could not have been considered by the Frank McCourt School Leadership Team (“SLT”) by November 12, 2010, as required by the emails. On October 6, 2010, Frank McCourt, being a brand new school, had not yet formed its SLT. The Frank McCourt PTA elected its first parent member on November 9, 2010. The first meeting of the Frank McCourt SLT was on December 7, 2010, therefore the SLT could not have provided feedback to the DOE by November 12", 3. Upon information and belief, the following list of projects at the Brandeis Campus have been completed by the School Construction Authority since 2001 Project Description Cap Category Description Completed Obligation FY04 RESO A UPGRADE 3 SCIENCE LABS Science Lab Upgrades 5/25/04 $1,080 EXTERIOR MODERNIZATION Exterior Modemnizations 5122107 $9,991,053 FULL UPGRADE SCIENCE LAB Science Lab Upgrades 9/18/05 $4,876,371 CLIMATE CONTROL Climate Control 2103/06 $1,383,627 FY0S RESO A MUSIC ROOM UPGRADE Miscellaneous 10/09/06 $287,280 WALK IN FREEZER REPLACEMENTS Walk-In Freezer Replacements 9/26/07 $329,487 IP SURVEILLANCE CAMERA INSTALLATION IP Surveillance Camera Installation 8/24/06 $439,220, IP CAMERA SURVEILLANCE/EXPANSION _IP Surveillance Camera Installation 9/20/08, $236,842 Total__ $17,544,960 114381924. Attached hereto as Exhibit 1 is a true and correct copy of Attachment 44-1 to the ‘Success Academy Charter School charter application. LISA Lac ‘Sworn to before me this 9" day of May 2011 in New York County Notary 1 yj 7 Neary He aw York Qualifies in Nee eee contin ep 67 07a 1143819.1EXHIBIT 1Charter Schools Institute % The State University of New York Proposal Transmittal Form 1, Schoo! Information Proposed Name of Charter School [Success Academy Charter School Proposed Location (School District or CSD & Region for NYC)|NYC CSD 3 Wnter Planned Enrollment & Grades Grades Served Proposed Enrollment Year 1 KL 188 Year 2 Ke 249 Year $ K3 401 ‘Year 4 Ke 574 ‘Year 5 Ko 689 Desired School Opening Date [August 2011 Desired Initial Charter Term {5 Years 2, Proposed Affiliations aucational Service Provider or Management Company (if any)}Success Charter Network, Inc. Public Contact Info (Name & Phone #) [Eva Moskowitz, (646) 747-6202 Partner Organization (if any) Public Contact [nfo (Name & Phone #) 3, Lead Applicant Contact Information Lead Applicant Name [Eva Moskowitz Mailing Address EE 02.85 10028 City [New York. ] state] zip coe owas carton, EE | on A) on. [(616) 747-6202 Lead Applicant Media/Public Contact Phone # (required) Lead Applicant Signature "Note: Authentisated Digital Signatures aecupted. Ifa handwritten signature ie sed, least one copy ofthe submitted propostl must bear fan original (eq. not photoenpied) signature. By signing this Propora! ‘Franotnittal Fora, the Lead Applicant certifios thatthe information contained in thin Proposal to establish charter school purauant to the ‘New York Charter Schools Act of 1998 (as amended) with the State Unversity of New York Boned of Trustca I tue and aecurate to tho be of his or her koowledge ‘Submit Completed Proposal to: Charter Schools Institute State University of New York 41 State Street, Suite 700 Albany, New York 12207 Phone: (518) 433-8277 Fax: (618) 427-6510 Web: www.newyorkcharters.org |FOR OFFICIAL USE ONLY: Received By: Date Receiveda bourd of Harlem Success Acidemy 3 since 2008 and dedicates his Ijpare time to improving education and child welfare and wellbeing. Elena Dilion ix # specialist in cognitive and language development ith ten years of classroom experience as a tencher and an ministrator with a xpecial focus on educational technolugy and [Enulch Language Learners,[Scott Gaynor has fourteen years experience as the head af a specutl X Iscott Gaynor leducation school and serves on the beards of the Guild of om ilindopendent Schools and the NYS Association of Independent Schools. Ee drew Feldstein is the co-founder and CEO/CIO of BlueMountain [Andrew Feldstein ‘apital. He has extensive experience in senior positions #t major |Gnancinl institutions and a law degree frim Harvard Law School. Lt. Lorenzo Smith is a graduate of West Point and a champion | Smith bobsled competitor. ARer attending Columbia Business School, he [joined the Market Risk group at the Federal Reserve Bank. Andrew Glaze is the founder of Emys Capital. He holds a CFA und has extensive knowledge and background in the Ginancial industry. |He previously served five years as an Artillery offiver in the United |Andrew Glaze J[Jarrett Posner is the COO of Argonaut Capital Management. where | Jhe transformed it from a small fund to a robust asset manager. Mr. fran” is a member of the Leadership Council for the Brown Annual lPund. ideon Stein is chair of the board of Harlem Success Academy 5. He fis a partner with Argyle Holdings and serves on the Board of [Directors of the Moriah Fund, among others. i | X fdarrett B. Posner44, Attach a description of the transportation arrangements made for charter ‘school students including arrangements made for students who would not qualify for public school transportation under Education Law Section 3635, and any supplemental transportation arrangements planned with the school district. ‘Since the school will be in session on days when the New York City public schools are pot in session and in hours outside of the NYC DOE normal hours of operation, itis impractical for students to use yellow bus service provided by the New York City School District to students attending nonpublic schools who would qualify under §2853(4)(b) and §3635 of the Education Law. However, families of students may arrange district transportation for themselves. Families will be responsible for arranging and providing transportation for students to and from the school. The school will help ease this burden by working with New York City Transit Authority to obtain student transportation passes as available Attachment 44-1