eCLAIM Receipt

You have successfully filed your claim.

By successfully filing your claim, you have certified that all information provided is true and correct to
the best of your knowledge and belief. You also understand that the willful making of any false
statement of material fact herein may subject you to criminal penalties and civil liabilities.

Please allow up to 30 days to receive an email acknowledging your claim.

If you have any questions please contact 212-669-3916.

Your Receipt Number is the following:

201800048573

You uploaded:
Claim Form: 1
Supporting Documents:5

10/8/2018 2:18 PM
Claimant Last Name:Teagle
Claimant First Name:Simone
 Office of the New York City Comptroller
1 Centre Street
New York City Comptroller
New York, NY 10007
Scott M. Stringer
Form Version: NYC-COMPT-BLA-PI1-D

Personal Injury Claim Form

Electronically filed claims must be filed at the NYC Comptroller's Website. If your claim is not resolved
within 1 year and 90 days from the date of occurrence you must start legal action to preserve your rights.

I am filing: Q On behalf of myself. ()Attorney is filing.

On behalf of someone else. If on someone else's Attorney Information (If claimant is represented by attorney)
'behalf, please provide the following information.
Firm or Last Name: The Sanders Firm, P.C.
Last Name:
Firm or First Name:
First Name:
Address: 30 Wall Street
Relationship to
the claimant: Address 2: 8th Floor
City: New York
State: NEW YORK
Claimant Information
Zip Code: 10005
*Last Name: Teagle
Tax ID:
*First Name: Simone
Phone #: (212) 652-2782
*Address:
*Email Address:
Address 2:
*Retype Email
*City: Address:
*State:
The time and place where the claim arose
*Zip Code:
*Date of Incident: 09/24/2018 Format: MM/DD/YYYY
*Country: USA
Time of Incident: 11:00a Format: HH:MM AM/PM
Date of Birth: Format: MM/DD/YYYY
*Location of 113th Precinct
Soc. Sec. # Incident:
HICN:
(Medicare #)
Date of Death: Format: MM/DD/YYYY
Phone:
*Email Address
*Retype Email
Address:
Occupation: NYPD Police Officer
City Employee? DYes No 0 NA
Gender Male ()Female °Other

Address: 167-02 Baisley Boulevard

Address 2:
City: Jamaica
*State: NEW YORK
Borough: QUEENS
*Denotes required fields. A Claimant OR an Attorney EmailAddress is required.
 Office of the New York City Comptroller
1 Centre Street
New York City Comptroller
New York, NY 10007
Scott M. Stringer

*Manner in which -SEE ATTACHED DOCUMENT-

claim arose:

*Denotes required field.

 Office of the New York City Comptroller
1 Centre Street
New York City Comptroller
New York, NY 10007
Scott M. Stringer

The items of $5 Million Dollars (Pain and Suffering, Mental Anguish and Punitive Damages)
damage or injuries
claimed are
(include dollar
. amounts):
 Office of the New York City Comptroller
1 Centre Street
New York City Comptroller
New York, NY 10007
Scott M. Stringer

Medical Information Witness 1Information

1st Treatment Date: Format: MM/DD/YYYY Last Name:

Hospital/Name: First Name:
Address: Address
Address 2: Address 2:
City: City:
State: State:
Zip Code: Zip Code: Phone:
Date Treated in Format: MM/DD/YYYY
Witness 2 Information
Emergency Room:
Was claimant taken to hospital by 0 Yes Q No ()NA Last Name:
an ambulance?
First Name:
Employment Information (If claiming lost wages) Address
Employer's Name: Address 2:
Address City:
Address 2: State:
City: Zip Code: Phone:
State: Witness 3 Information
Zip Code:
Last Name:
Work Days Lost:
First Name:
Amount Earned
Weekly: Address
Address 2:
Treating Physician Information
City:
Last Name:
State:
First Name:
Zip Code: Phone:
Address:
Address 2: Witness 4 Information

City: Last Name:

State: First Name:
Zip Code: Address
Address 2:
City:
State:
Zip Code: Phone:
 Office of the New York City Comptroller
1 Centre Street
New York City Comptroller
New York, NY 10007
Scott M. Stringer

Complete if claim involves a NYC vehicle

Owner of vehicle claimant was traveling in Non-City vehicle driver

Last Name: Last Name:

First Name: First Name:
Address Address
Address 2: Address 2:
City: City:
State: State:
Zip Code: Zip Code:

Insurance Information Non-City vehicle information

Insurance Company Make, Model, Year
Name: of Vehicle:
Address Plate #:
Address 2: VIN #:
City:
City vehicle information
State:
Plate #:
Zip Code:
Policy #:
Phone #: City Driver Last
Name:
Description of 0 Driver 0 Passenger City Driver First
claimant: Name:
0 Pedestrian 0 Bicyclist
Motorcyclist ®Other

Total Amount Format: Do not include "$" or ",".

$5,000,000.00
Claimed:

The Total Amount Claimed can only be entered once the following
required fields are entered:

Claimant Last Name

Claimant First Name
Claimant Address,City,State,Zip Code, and Country
Claimant Email or Attorney Email
Date ofIncident
Location ofIncident (including State)
Manner in which claim arose

I certify that all information contained in this notice is true and correct to the best ofmy knowledge and belief. I understand that the willful
making ofany false statement ofmaterial fact herein will subject me to criminalpenalties and civil liabilities.
Claimant alleges that while assigned to the 113th Precinct, since February 2018, Respondents'
THE CITY OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN has failed and refused
to provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk.

Claimant alleges that under The Patient Protection and Affordable Care Act (P.L. 111-148,
known as the "Affordable Care Act") amended section 7 of the Fair Labor Standards Act
("FLSA") to require employers to provide "reasonable break time for an employee to express
breast milk for her nursing child for 1 year after the child's birth each time such employee has
need to express the milk."

Claimant alleges that under the Affordable Care Act, employers are also required to provide "a
place, other than a bathroom, that is shielded from view and free from intrusion from coworkers
and the public, which may be used by an employee to express breast milk." See 29 U.S.C. 207(r).

Claimant alleges that under the Affordable Care Act, the FLSA requirement of break time for
nursing mothers to express breast milk does not preempt State Laws that provide greater
protections to employees (for example, providing compensated break time, providing break time
for exempt employees, or providing break time beyond 1 year after the child's birth).

Claimant alleges that since February 2018, Respondent THE CITY OF NEW YORK is not in
compliance with the Affordable Care Act.

Claimant alleges that under New York State Labor Law Section 206-c guarantees nursing mothers
break time to pump breast milk at work.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer is required but, is
not in compliance with the New York State Labor Law Section 206-c.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer is required but,
DOES NOT inform female employees who are nursing mothers returning to work following the
birth of a child about their right to take unpaid leave for pumping breast milk by placing a public
poster in the workplace, promulgate a policy within the NYPD Patrol Guide or other employee
handbook or notifying the individual female employees in writing.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that she may take break time to
pump breast milk at work for up to three years following the birth of her child.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers they are entitled to at least 20
minutes for each break.
Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that they may take shorter breaks if
they chose.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that they must be allowed more
time if they need it.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT allow female employees who are nursing mothers to take breaks at least once every
three hours to pump breast milk.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that they may take these breaks
right before or after their regularly scheduled paid break or meal periods.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that if they take breaks to pump
breast milk, it cannot deduct that time from her regular paid break or meal time.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers they are entitled to work before or
after their normal shifts to make up for the break time they take to pump breast milk, as long as that
time falls within the employer's normal work hours.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers they have the option of using their
regular paid break or meal time to pump breast milk, but they are not required to do so.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers it is required to provide employees
with a private room or other location close to the employee's work area where they can pump breast
milk, unless it would be extremely difficult for it to do so.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers if it cannot provide a dedicated
lactation room, a temporarily vacant room may be used instead.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers as a last resort, a cubicle can be
used, but it must be fully enclosed with walls at least seven feet tall.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers the room or location provided by
an employer to pump breast milk cannot be a restroom or toilet stall.

2
Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that the place where employees
pump breast milk must contain a chair and small table or other flat surface.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that The Department of Labor
encourages employers to provide, in addition, an electrical outlet, clean water supply, and access to
a refrigerator where nursing mothers can store pumped milk.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that the room or place provided by
the employer cannot be open to other employees, customers, or members of the public while an
employee is pumping breast milk.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers it should have a door with a
functional lock, or in the case of a cubicle, a sign warning the location is in use and not accessible to
others.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that employers may not
discriminate or retaliate in any way against any employee who chooses to pump breast milk in the
workplace or who files a complaint with the Department of Labor.

Claimant alleges that Respondent THE CITY OF NEW YORK as an employer, is required but
DOES NOT inform female employees who are nursing mothers that any party may file a
confidential complaint with the United States Equal Employment Opportunity Commission, United
States Department of Labor and/or the New York State Department of Labor's Division of Labor
Standards alleging non-compliance with the law.

Claimant alleges that while assigned to the 113th Precinct, since February 2018, Respondents'
THE CITY OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN has failed and refused
to provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk she now suffers from severe engorgement and Mastitis.

Claimant alleges that while assigned to the 113th Precinct, since February 2018, Respondents'
THE CITY OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN has failed and refused
to provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk she has to express milk in-front of other female officers.

Claimant alleges that while assigned to the 113th Precinct, since February 2018, Respondents'
THE CITY OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN has failed and refused

3
to provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk she has to pump in a female bathroom.

Claimant alleges that while assigned to the 113th Precinct, since February 2018, Respondents'
THE CITY OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN has failed and refused
to provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk she has to pump in a the female locker room.

Claimant alleges that while assigned to the 113th Precinct, since February 2018, Respondents'
THE CITY OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN has failed and refused
to provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk she has to express milk in her personal vehicle.

Claimant alleges that while assigned to the 113th Precinct, since February 2018, Respondents'
THE CITY OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN has failed and refused
to provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk she has to store the expressed milk in a lunchbox inside of her personal
vehicle.

Claimant alleges that while assigned to the 113th Precinct, on or about April 19, 2018, she
contacted the NYPD Office of Equal Employment Opportunity about Respondents' THE CITY
OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN failure and refusal to
provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk.

Claimant alleges that while assigned to the 113th Precinct, on or about April 19, 2018, she was
instructed her to fill out for Request for a Reasonable Accommodation.

Claimant alleges that shortly thereafter, Agency Attorney Andrew Vacca, NYPD Office of Equal
Employment Opportunity specifically tasked with the express milk legal issues told her that he
would speak with her Integrity Control Officer (Respondent JOZEF BAN) and the Commanding
Officer (JERRY 0' SULLWAN) about her legal rights.

Claimant alleges that shortly thereafter, Agency Attorney Andrew Vacca, NYPD Office of Equal
Employment Opportunity told her that he was unable to reach Respondents' JERRY
O' SULLIVAN or JOZEF BAN.

Claimant alleges that from April 19, 2018, through August 28, 2018, since Respondents' THE
CITY OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN has failed and refused
to provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk she has to express milk in-front of other female officers, she has to pump

4
in a female bathroom, she has to pump in a the female locker room, she has to express milk inside
of her personal vehicle and store the expressed milk in a lunchbox inside of her personal vehicle.

Claimant alleges on or about August 28, 2018, Respondent ROXANNE LUDEMANN asked to
speak with her.

Claimant alleges that Respondent ROXANNE LUDEMANN told her that if she wanted to take a
`breast pump' break that she needed to make an entry into the Interrupted Patrol Log.

Claimant alleges that she informed Respondent ROXANNE LUDEMANN that she is a member
of the administrative staff and that no other member MUST write their personal breaks in the
Interrupted Patrol Log. Also, that the Interrupted Patrol Log used to monitor patrol personnel that
enter the stationhouse during the tour.

Claimant alleges later that day, she met with Respondent KURT NASON informing him of the
instructions given to her by Respondent ROXANNE LUDEMANN.

Claimant alleges that she told Respondent KURT NASON supervisors at the 113th Precinct
including Respondent ROXANNE LUDEMANN are harassing and retaliating against her for
asserting her legal right to express milk but, he failed to notify the NYPD Office of Equal
Employment Opportunity.

Claimant alleges that she told Respondent KURT NASON that she again contacted the NYPD
Office of Equal Employment Opportunity about her legal right to express milk.

Claimant alleges that she spoke with Respondent MARIA GILBERT, assigned to the NYPD
Office of Equal Employment Opportunity.

Claimant alleges that Respondent MARIA GILBERT told her to fill out another Request for a
Reasonable Accommodation detailing the times periods she expresses milk as well as the length
of time used to express milk.

Claimant alleges that although she disagreed with Respondent MARIA GILBERT'S instructions
as violative of the law, she filled out the form had it signed by Respondent JOZEF BAN and sent
it to Respondent MARIA GILBERT via Department Mail.

Claimant alleges that from August 28, 2018, through September 17, 2018 since Respondents'
THE CITY OF NEW YORK; BILL de BLASIO; LISETTE CAMILO (Department of Citywide
Administrative Services) JAMES P.O'NEILL and JERRY'OSULLIVAN has failed and refused
to provide her and other similarly situated female employees who are nursing mothers with a proper
location to express milk she has to express milk in-front of other female officers, she has to pump
in a female bathroom and she has to pump in a the female locker room.

Claimant alleges that on or about September 17, 2018, in retaliation for her complaints,
Respondent JERRY 0' SULLWAN summarily transferred her from the 113th Precinct to another
department facility.