Stapon V. Riverhead Central School District Et Al

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

X
ANASTASIA STAPON,
Plaintiff,
-against-
RIVERHEAD CENTRAL SCHOOL DISTRICT, VERIFIED COMPLAINT

CHARLES REGAN, AURELIA L. HENRIQUEZ,
SUSAN KOUKOUNAS, CHRISTOPHER DORR,
LAURIE DOWNS, GREGORY MEYER,
ELIZABETH C. SILVA, THERESE ZUHOSKI a/k/a
THERESE FERGUSON, BRIAN CONNELLY,
PAUL R. DOYLE, JOSEPH OGEKA, JR.,
NANCY CARNEY, JAMES MCCAFFREY,
LORI M. HULSE, NANCY GASSERT,
W. BRIAN STARK, KATHLEEN BEREZNY,
ELLEN HARKIN, TIMOTHY GRIFFING,
CHRISTINE PRETE, and ANGELA DEVITO,
Defendants.
X
Plaintiff, ANASTASIA STAPON, by her attorneys, Ray,‘Mitev & Associates, LLP,
appears and complains as follows:
PARTIES
I. At all relevant times, Plaintiff is over the age of 18 and resides in the County of
Suffolk.
2. At all relevant times, upon information and belief, Riverhead Central School
District (hereafter “RCSD”) is a New York State public school district created and existing under
and by virtue of the laws of the State of New York, with offices in and located in Suffolk
County, New York.
3. At all relevant times, Riverhead High School was and is a public school operating
as a high school in the Riverhead Central School District.

4. At all relevant times, individual Defendants are or were agents or employees of
Riverhead Central School District.
5. In the school year 2018-2019, Defendant Aurelia L. Henriquez was and is
Superintendent of Riverhead Central School District.
6. Upon information and belief, at all relevant times, Defendant Aurelia L.
Henriquez was and is a resident of Suffolk County, New York.
7. In the school year 2018-2019, Defendant Susan Koukounas was President of the
Board of Education for Riverhead Central School District.
8. Upon information and belief, at all relevant times, Defendant Susan Koukounas
was and is a resident of Suffolk County, New York.
9. In the school year 2018—2019, Defendant Christopher Dorr was Vice President of
the Board of Education for Riverhead Central School District.
10. Upon information and belief, at all relevant times, Defendant Christopher Dorr
11. In the school year 2018—2019, Defendant Laurie Downs was a member of the
12. Upon information and belief, at all relevant times, Defendant Laurie Downs was
and is a resident of Suffolk County, New York.
13. In the school year 2018—2019, Defendant Gregory Meyer was a member of the
14. Upon information and belief, at all relevant times, Defendant Gregory Meyer was

15. In the school year 2018-2019, Defendant Elizabeth C. Silva was a member of the
16. Upon information and belief, at all relevant ”times, Defendant Elizabeth C. Silva
17. In the school year 2018-2019, Defendant Therese Zuhoski was a member of the
18. Upon information and belief, at all relevant times, Defendant Therese Zuhoski
19. In the school year 2018—2019, Defendant Brian Connelly was a member of the
20. Upon information and belief, at all relevant times, Defendant Brian Connelly was
21. In the school year 2018—2019, Defendant Charles Regan was Principal of
Riverhead High School.
22. Upon information and belief, Charles Regan was hired as Assistant Principal of
Riverhead High School in or about June 2006.
23. Upon information and belief, Charles Regan was hired on an “Emergency 20—day
Conditional Appointment,” and that at that time of his hiring, Charles Regan’s resume and level
of expertise was neither seen by, nor known by, at least one member on the Board of Education
for Riverhead Central School District.
24. Upon information and belief, Charles Regan’s employment as an agent or
employee of Riverhead Central School District was approved by the Superintendent of

Riverhead Central School District, and by the Board of Education for Riverhead Central School
District, at a Board of Education meeting having taken place on June 27, 2006.
25. Upon information and belief, Charles Regan’s employment as an agent or
employee of the Riverhead Central School District became effective on or about July 1, 2006.
26. Upon information and belief, at all relevant times, Charles Regan was and is a
resident of Suffolk County.
27. In or about June 2006, upon information and belief, Defendant Paul R. Doyle was
Superintendent of Riverhead Central School District.
28. Upon information and belief, at all relevant times, Defendant Paul R. Doyle was
29. In or about June 2006, upon information and belief, Defendant Joseph Ogeka, Jr.
was Assistant Superintendent for Personnel and Community for Riverhead Central School
District.
30. Upon information and belief, at all relevant times, Defendant Joseph Ogeka, Jr.
31. In the school years 2005-2007, upon information and belief, Defendant Nancy
Carney was Assistant Superintendent for Curriculum & Instruction for Riverhead Central School
District.
32. Upon information and belief, at all relevant times, Defendant Nancy Carney was
33. In the school years 2004-2006, upon information and belief, Defendant James
McCaffrey was Principal of Riverhead High School.

34. Upon information and belief, at all relevant times, Defendant James McCaffrey
35. In the school year 2005 ~2006, upon information and belief, Defendant Lori M.
Hulse was President of the Board of Education for Riverhead Central School District.
36. Upon information and belief, at all relevant times, Defendant Lori M. Hulse was
37. In the school year 2005-2006, upon information and belief, Defendant Nancy G.
Gassert was Vice President of the Board of Education for Riverhead Central School District.
38. In the school year 2006-2007, upon information and belief, Defendant Nancy G.
Gassert was President of the Board of Education for Riverhead Central School District.
39. Upon information and belief, at all relevant times, Defendant Nancy G. Gassert
40. In the school year 2005-2006, upon information and belief, Defendant W. Brian
Stark was a member of the Board of Education for Riverhead Central School District.
41. In the school year 2006—2007, upon information and belief, Defendant W. Brian
Stark was Vice President of the Board of EduCation for Riverhead Central School District.
42. Upon information and belief, at all relevant times, Defendant W. Brian Stark was
43. In the school years 2005-2007, upon information and belief, Defendant Kathleen
Berezny was a member of the Board of Education for Riverhead Central School District.
44. Upon information and belief, at all relevant times, Defendant Kathleen Berezny

45. In the school years 2005-2007, upon information and belief, Defendant Ellen
Harkin was a member of the Board of Education for Riverhead Central School District.
46. Upon information and belief, at all relevant times, Defendant Ellen Harkin was
47. In the school years 2005—2007, upon information and belief, Defendant Timothy
Griffing was a member of the Board of Education for Riverhead Central School District.
48. Upon information and belief, at all relevant times, Defendant Timothy Griffing
49. In the school years 2005—2007, upon information and belief, Defendant Christine
Prete was a member of the Board of Education for Riverhead Central School District.
50. Upon information and belief, at all relevant times, Defendant Christine Prete was
51. In the school year 2006—2007, upon information and belief, Defendant Angela
DeVito was a member of the Board of Education for Riverhead Central School District.
52. Upon information and belief, Defendant Angela DeVito was and is a resident of
Suffolk County, New York.
53. At all times herein, Plaintiff is and was a senior student in the 12th grade at
Riverhead High School.
JURISDICTION
Jurisdiction is proper because this case is brought, inter alia, pursuant to federal statutes
20 USC §168l et seq. (Title IX), and 42 USC §1983.

VENUE
Venue is properly in this District because the acts alleged herein all arose and occurred in
this District, and all the parties resided in or were located in this Eastern District of New York
when these acts arose and occurred.
ALLEGATIONS
54. In and around January 8, 2019 and continuing until April 30, 2019, Defendant
Regan exercised his position and authority and powers over students, including Plaintiff, in his
employment as the Principal of Riverhead High School.
55. From around January 8, 2019 and continuously until April 30, 2019, Defendant
Regan knowingly, willfully misused his position, authority and powers in order to sexually
harass, sexually seduce, assault, batter, and sexually abuse Plaintiff.
56. In the school year 2018-2019, Plaintiff suffered deep mental depression.
57. In the school year 2018—2019, Plaintiff had become a frequent user of marijuana
and alcohol.
58. Plaintiff would frequently use marijuana and alcohol in and out of school, before,
during and after school

hours
59. At all times herein, by reason of Plaintiff’s deep depression and use of marijuana
and alcohol, Plaintiff was in need of assistance Via teachers, administrators, a counselor and/or
mental health professional, including at least one or several to have been provided to Plaintiff in
and by Defendant District.

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60. At all times herein, Defendants knew and/or should have known of Plaintiffs
aforesaid state of mind and need, and of Plaintiffs use of marijuana and alcohol.
61. At all times herein, Defendants had a duty to have learned of Plaintiffs state of
mind and need, and of Plaintiffs use of marijuana and alcohol in and out of school.
62. At all times herein, Defendants had a duty to provide Plaintiff with guidance and
assistance via teachers, a counselor and/or mental health professional including at least one or
several such professional persons, as to Plaintiffs aforesaid state of mind and need, and as to
Plaintiffs use of marijuana and alcohol in and out of school.
63. At all times herein, Defendants breached and neglected Defendants’ duties
aforesaid.
64. Instead, at all times herein, Defendants provided Plaintiff and imposed upon
Plaintiff the counseling, services and attentions of Defendant Charles Regan, a sexual predator
serving as the school principal.
65. At all times herein, Defendants knew and/or should have known that Defendant
Regan was a sexual predator who sexually preyed upon young girl students under his charge as
principal.
66. At all times herein, Defendants knew and/or should have known that Defendant
Regan had been a sexual predator who sexually preyed upon young girl students under his
charge when Defendant Regan had been employed as a teacher in South Manor schools and
Eastport/South Manor schools, and upon information and belief, when he was employed as a
teacher and “Dean” at B.O.C.E.S.

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67. At all times herein, in full view and with the complicity and collusion of
Defendants, Defendant Regan sexually groomed Plaintiff for his sexual harassment, sexual
assault, battery, and abuse.
68. To effect his sexually perverse purposes, Regan gave extraordinary time and
attention to Plaintiff in full view of and with the complicity and collusion of Defendants,
misusing his position and authority as a principal to do so, with the overweening sexual
grooming tactics and purposes that Defendant Regan would:
a. Cause Plaintiff to rely solely upon Regan as her counselor and mentor;
b. Cause Plaintiff to become substantially and entirely dependent upon
Regan in Regan’s authoritative and official position, as a person in place of her
parents(“in loco parentis”), and as her father figure and father substitute who
would assist Plaintiff in coping with her depression and debilitated state of mind,
and with her use of marijuana and alcohol;
c. Cause Plaintiff to rely upon Defendant Regan to shield and protect her
from disciplinary measures in school for using marijuana or alcohol therein, and
for missing classes or portions thereof Plaintiff was otherwise obliged to attend,
and unlawfully alter her attendance record in her favor, and created and
performed Plaintiffs homework for Plaintiff, to be falsely submitted to teachers
as Plaintiff s homework;
d. Cause, cajole, persuade, inveigle, overreach and deceive Plaintiff to
develop affection for and love for Defendant Regan, and concomitant physical
and emotional attachment to and attraction for Defendant Regan;

e. Disarm Plaintiff of and suppress psychological, mental and emotional and
physical defenses which Plaintiff would otherwise have had against Defendant
Regan’s sexual grooming and sexual predatory advances and sexual conduct and
sexual grooming conduct;
f. Prepare Plaintiff and cause Plaintiff to be vulnerable to Defendant Regan’s
sexually perverse attentions and sexual predatory conduct and sexual grooming
conduct;
g. Cause, cajole, persuade, inveigle, overreach and use undue influence upon
Plaintiff to accept and engage in Defendant Regan’s sexually perverse attentions
and sexually predatory conduct and sexually grooming in school and in his office
and in texts via cell phone communication;
h. Isolate Plaintiff from her parents, sister, girlfriends and boyfriends, and
school counselors and teachers, so that the Plaintiff would be caused to
overwhelmingly give Defendant Regan her undivided attention and reliance, for
him to engage in sexual perversion sexual advances, sexually predatory conduct
and in sexual grooming as to Plaintiff;
i. Falsely and deviously convince Plaintiff that Defendant Regan would
leave his wife and children for Plaintiff in order to convince Plaintiff to accept his
sexually perverse conduct, sexual advances, sexual predatory conduct and sexual
grooming;
j. Cause Plaintiff to be in fear of Defendant Regan and Defendant Regan’s
exercise of his authority and undue influence over Plaintiff, in order that Plaintiff
would submit to Defendant Regan’s sexually perverse words and acts and
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sexually predatory conduct and sexual grooming, and so that Plaintiff would not
reveal Defendant Regan’s sexually perverse words and acts to anyone;
k. Cause Plaintiff to be in fear of Defendant Regan’s physical violence,
including by texting Plaintiff violent threats and death threats against students
who had allegedly expressed what Defendant Regan perceived to be romantic or
personal interests in Plaintiff, and against Defendant Regan’s own six-year old
daughter of whom Regan perversely and atrociously sent a photo to Plaintiff, in
order to impress upon Plaintiff and cause Plaintiff to believe that Defendant
Regan had the capacity and will to commit such heinous acts. Defendant Regan
sought to create, and created, this impression upon Plaintiff in order to overawe
Plaintiff with fear and regard for Defendant Regan so that Plaintiff would submit
to and accept Regan’s sexually predatory conduct, sexual perverse words and
acts, and sexual grooming, and to further isolate Plaintiff and cause Plaintiff to
abandon and avoid friendships and family members; and perversely to cause
Plaintiff to believe that Defendant Regan’s small child was discardable by Regan
for all of the aforesaid reasons.
1. Cause Plaintiff to fear Defendant Regan and intimidate Plaintiff, and to
inordinately depend upon Defendant Regan, and to isolate Plaintiff by causing
Plaintiff to be separated from relationships with her friends, by walking Plaintiff
from the high school to her vehicle almost daily when the school day ended, from
January 2019 through April 29, 209.
69. In order to fulfill Defendant Regan’s aforesaid illicit, sexually perverse purposes
Defendant Regan:
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a. Did in fact cause Plaintiff to give up her duly assigned school counselor
and private counselor in or about January -
April 2019, and instead substituted
himself as Plaintiff’s only counselor, using his authority and the

position as
school principal, and acting as Defendants’ agent, to do so;
b. Did in fact cause Plaintiff’s sister to be moved out of Riverhead High
School and into Sagamore School, in order to isolate Plaintiff as aforesaid;
c. From January 2019 through April 29, 2019, Defendant Regan did in fact
repeatedly cause Plaintiff to enter his principal’s office at Riverhead High School
in full view of Defendants and their agents and and of the

employees security
cameras and devices, and of Defendants” agents and employees and those who
were responsible to monitor said devices thereabout, and remain therein during
school hours in full knowledge of, and with the complicity and collusion of
Defendants. This occurred on a daily basis, including at intervals several times per
day, whereupon Defendant Regan caused Plaintiff to remain in his office for
extended periods of time, using each of these visits to engage Plaintiff in
conversations designed by Regan to accomplish all of the aforesaid illicit
purposes. On many such occasions, Defendant closed his office doors in order to
carry out the aforesaid purposes without hindrance or view by other persons;
d. From January 2019 through April 2019, Regan did in fact, in full View of
Defendants, their agents and employees and of the security devices and those of
Defendants’ agents who were responsible to monitor said devices, cause the door
windows to his office to be covered with blocking or screening material such that
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the said windows were blocked, and no one could View what occurred in
Defendant’s office when the doors were closed.

I
e. In or about April 2019, Regan grossly improperly kissed Plaintiff upon her
head while he and Plaintiff were in Regan’s office. His kiss was not requested or
invited. Regan’s purpose in delivering this kiss was for all illicit and aforesaid
purposes.
f. From January 2019 through April 29, 2019, Defendant engaged in the
improper sending and receiving of thousands of sexually charged text messages
and Facetime calls to and from Plaintiff, such that, by way of example, about at
least 12,000 were sent and received by Regan in the period 3/30/2019 through
4/29/2019. Such text messages and Facetime calls were conveyed via Regan’s
partially District-funded personal cell phone and via an official school-issued cell
phone. Such text messages and Facetime calls were sent and received during
school hours and during non-school hours, including but not limited to evening
hours, early morning hours and school vacation hours, for all of the aforesaid
sexually improper purposes.
g. From January 2019 through April 29, 2019, Defendant engaged in
numerous improper telephone calls with Plaintiff, during school hours and during
non—school hours. During such telephone calls, Defendant Regan would use
Defendants’ school landline phones, and the official school-issued cell phone and
Regan’s partially District funded personal cell phone. At all times herein Regan
received District payment characterized by Defendants as a “stipend,” for Regan’s
use of his personal cell phone in Regan’s capacity as a District-employed HS.
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Principal. Defendants knew and should have known of Defendant Regan’s
prodigious use of District phones and Defendant Regan’s use of his District paid
for personal phone, for his inordinate telephone communication with Plaintiff.
h. From January 2019 through April 29, 2019, Regan’s text messages to
Plaintiff improperly included thousands of sexually-charged and sexually explicit
messages and photo snapshots from Regan to Plaintiff, including by way of
example, a photo of Regan’s naked body wherein his penis is covered by a
vertical thin strip of cloth; messages explicitly encouraging Plaintiff to engage in
masturbation for him and with him; messages urging Plaintiff to have sex with
Regan; messages urging Plaintiff to view pornography; messages encouraging
Plaintiff to fantasize about sex and romance with Regan and with others including
administrative colleagues. Each such text message directly gives rise to causes of
action as against Defendants, but same are too cumbersome and voluminous to
separately set forth in this complaint. The texts from 3/30/19 through 4/29/19 are
attached as Schedule 1 and made a part of this Complaint. The photos sent by
Regan to Plaintiff are attached as Schedule 2 and made part of this Complaint.
i. From January 2019 through April 29, 2019, Regan sent to Plaintiff
sexually-charged videos, including by way of example, video depiction of couples
engaged in intimate embrace and in simulated sex. Each such video gives rise to
discrete causes of action as against Defendants, but due to the nature thereof,
same are not capable of being attached to this Complaint.
j. From January 2019 through April 29, 2019, Defendant Regan sent text
messages to Plaintiff, received by Plaintiff, wherein Regan threatened to harm
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and/or kill certain students who Regan believed had formed or were forming a
personal relationship with Plaintiff, sent by Regan for the aforesaid intentions.
k. In or about April 2019, Defendant Regan improperly and perversely sent a
photo to Plaintiff which depicted Regan’s six year old daughter. In the same
month Regan sent Plaintiff a text message wherein Regan inferred that this
daughter angered him such that he would kill his daughter which, he suggested,
would greatly please his older child. This was sent by Regan for all the perverse
reasons aforesaid.
1. From January 2019 through April 29, 2019, at various times during the
school day, upon information and belief Regan in his capacity as Principal and
agent of Defendants, altered and falsified Plaintiff‘s attendance records kept by
the Defendants to falsely indicate that Plaintiff was in attendance in school during
times when Plaintiff was not so. This was done by Regan for all of the reasons
aforesaid. The Defendants knew and should have known that Defendant Regan
had falsified Plaintiff’s attendance records as aforesaid, but instead Defendants
were complicit in and colluded in these wrongful and unlawful acts.
m. From January 2019 through April 29, 2019, at various times during the
school day, Defendant Regan performed and created Plaintiffs homework
assignments and urged and used Plaintiff to submit such work as her own to
Plaintiff’ 5 teachers, for all of the aforesaid wrongful purposes.
n. On or about 4/29/19 during the school day, Defendant Regan, in full View
of Defendants’ agents and employees, cajoled and persuaded Plaintiff to enter into
and remain in his office in order that Defendant Regan could sexually harass,
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sexually assault, batter and sexually abuse Plaintiff, and engage Plaintiff in
Regan’s sex acts. Defendants had a duty to report this improper conduct to school
authorities and to prevent the occurrences thereof, but have failed and refused to
do so.
0. On or about 4/29/19 during the school day, Defendant Regan sexually
assaulted Plaintiff in his office by physically, deliberately, approaching Plaintiff,
looming over Plaintiff, and reaching out for Plaintiff with his hands in order to
sexually abuse Plaintiff, causing in Plaintiff fear, intimidation, anxiety,
apprehension of harm, immobility, loss of freedom, enervation, emotional distress
and suffering.
p. On or about 4/29/19 during the school day, Defendant Regan sexually
battered Plaintiff in his office by physically, deliberately grasping Plaintiff by her
neck, pulling Plaintiff by her neck towards him, pressing his body against her,
maneuvering his mouth unto her lips, covering her lips with his mouth, then
shoving his tongue into her mouth; with the intention to commit sex acts against
Plaintiff, and thereby intentionally, willfully, committing the first sex acts of those
other sex acts upon Plaintiff he intended. This caused in Plaintiff fear,
intimidation, anxiety, immobility, loss of freedom, enervation,‘ disgust, revulsion,
alarm, terror, dread, emotional distress, panic, trembling, apprehension of harm,
abhorrence, and suffering.
q. On or about 4/29/19 during the school day and after Regan sexually
battered Plaintiff, Defendant Regan improperly text-messaged Plaintiff wherein
Regan explored and enquired whether Plaintiff enjoyed and accepted this assault
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and battery upon Plaintiff by Regan. This text message was intended by
Defendant Regan to intimidate, frighten, cajole and entrap Plaintiff into i) ex post
facto consent to and approval of the aforesaid the sexual abuse, assault and battery
of Plaintiff by Regan ii) submitting to further sexual abuse, assault and battery by
Regan; and Plaintiff was thereby intimidated, frightened, disgusted, revulsed,
alarmed, terrorized, distressed, caused to suffer apprehension and foreboding that
Regan would exercise his power and authority as H.S. Principal to do harm to her
if she didn’t comply with his illicit wishes, and caused Plaintiff to panic and to
suffer emotionally and physically.
r. On or about 4/29/19, during the school day and after Regan sexually
battered Plaintiff, in full View of Defendants’ agents and employees, Defendant
Regan caused Plaintiff to enter his office in order to compel, cajole and overreach
Plaintiff to cooperate with Regan to cover up Regan’s illicit acts and texts and
photos, and destroy evidence of Regan’s illicit acts and texts and photos, and to
intimidate, frighten, cajole and overreach Plaintiff into consent and approval of
the sexual abuse, assault and battery of Plaintiff by Regan, and into destroying the
text messages and photo evidence of Regan’s aforesaid illicit behaviors by
deleting said texts and photos from Plaintiffs cell phone, and by lying to any
authority, including but not limited to Plaintiff’s parents, to conceal Regan’s illicit
behaviors.
s. On or about 4/29/19 during the school day, in Defendant Regan’s office,
Regan compelled, cajoled, and overreached Plaintiff to engage in covering up
Regan’s illicit acts and texts and photos, and destroy evidence of Regan’s acts,
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texts and photos. At his direction and with his assistance, Plaintiff deleted texts
and photos from her cell phone, and under Regan’s aforesaid urging, direction,
and pressure, agreed to lie to authorities to conceal Regan’s illicit behaviors.
These acts by Regan were intended to and did cause Plaintiff to be frightened,
alarmed, terrorized, distressed, to suffer foreboding and apprehension, panic,
emotional and physical distress.
t. Defendant Regan caused Plaintiff to fear Defendant Regan and to be
intimidated by Regan, and to feel isolated and vulnerable to Regan, and to be
separated from Plaintiff’s friends, by walking Plaintiff from the high school to her
vehicle almost daily when the school day ended, in full view of students, teachers
and administrators, from January 2019 through April 29, 2019.
70. At all times herein, Defendants had a duty to protect Plaintiff as a student in
Defendants’ high school from all of the aforesaid illicit behaviors by Defendant Regan,
and Defendants failed, neglected, and refused to do so.
71. At all times herein Defendants were responsible for and liable for the acts of their
agents and employees including Defendant Regan, in the course of their employment.
AS FOR A FIRST CAUSE OF ACTION:

SEXUAL ASSAULT
72. By reason of the foregoing, Defendant Regan sexually assaulted Plaintiff.
73. By reason of the foregoing, Defendants are liable for the sexual assault upon
Plaintiff, in that at all times herein Defendants were responsible for and liable for the acts
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of their agents and employees including Defendant Regan, in the course of their
employment.
74. By reason of the foregoing, Plaintiff has been damaged by Defendants in that
Plaintiff has suffered intimidation, apprehension, foreboding of harm, panic, depression,
physical and emotional damage, invasion of her privacy, humiliation, degradation and
loss of dignity, all to her damages in a sum to be determined by the trier of fact.
AS FOR A SECOND CAUSE OF ACTION:

SEXUAL BATTERY
75. By reason of the foregoing, Defendant Regan sexually battered Plaintiff.
76. By reason of the foregoing, Defendants are liable for the sexual battery against
employment.
AS FOR A THIRD CAUSE OF ACTION:

SEXUAL ABUSE
78. By reason of the foregoing, Defendant Regan sexually abused Plaintiff.
l9
79. By reason of the foregoing, Defendants are liable for sexual abuse of Plaintiff in
that at all times herein Defendants were responsible for and liable for the acts of their
AS FOR A FOURTH CAUSE OF ACTION:

SEXUAL HARASSMENT
81. By reason of the foregoing, Defendant Regan sexually harassed Plaintiff.
82. By reason of the foregoing, Defendants are liable for sexual harassment of
employment.
physical emotional damage, invasion of her privacy, humiliation, degradation and

and
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AS FOR A FIFTH CAUSE OF ACTION:
VIOLATION OF TITLE IX, 20 USC§1681 et seq.
84. Plaintiff repeats paragraphs 1 -
75 herein.
85. At all times each of Defendants had the authority, individually and collectively, to
institute corrective measures on behalf of Defendant District to interfere with, cause
cessation of, impede, and otherwise prevent or thwart a) Defendant Regan’s illicit sexual
grooming techniques used upon Plaintiff and other students; b) Defendant Regan’s
aforesaid threatening behaviors; 0) Defendant Regan’s improper aforesaid relationship
imposed upon Plaintiff; d) Defendant’s sexual harassment of Plaintiff, sexual abuse of
Plaintiff, sexual assault upon Plaintiff, sexual battery of Plaintiff; e) Defendant’s willful
aforesaid conduct in using Plaintiff as his agent in causing Plaintiff to erase electronic
information on Plaintiff’s cellphone in order to conceal his aforesaid unlawful conduct.
86. Each of Defendants at all times herein failed and refused to exercise their
individual and/or collective authority to interfere with, cause cessation of, impede and
otherwise prevent or thwart Defendant Regan’s aforesaid unlawful behaviors, and to
protect Plaintiff and her welfare, and that of other students.
87. Each of Defendants at all times herein exercised and demonstrated deliberate
indifference and reckless indifference: a) to each of Defendant Regan’s aforesaid
unlawful acts and behaviors; b) as to Plaintiff’s welfare and that of other students in the
Defendant District.
88. Each of Defendants had an individual and/or collective obligation to have
supervised and monitored H.S Principal Regan in his relationship with Plaintiff and with
other students.
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89. Defendant District at all times, is and was a public school district receiving
various federal funds, subject to 20 USC§1681 et seq.
90. Upon information and belief, at all times herein, it was a policy, custom or
practice of Defendants individually and collectively to exercise and demonstrate
deliberate indifference and reckless indifference as to the behaviors of administrators,
including Defendant Regan a) in relation to students including Plaintiff and b) as to the
personal relationships of administrators, including Defendant Regan, with students,
including Plaintiff.
91. By reason of the foregoing, Defendant Regan, being free from Defendants’
individual and collective scrutiny and supervision, and from exercise of Defendants’
individual and collective authority as aforesaid, was enabled to engage in and maintain
for a substantial time, the aforesaid unlawful conducts and relationships with Plaintiff and
other students, with impunity.
92. By reason of the foregoing, Defendants’ breaches of their aforesaid duties and
obligations caused the aforesaid harms to Plaintiff insofar as sexual predator, harasser,
assaulter, batterer, sexual groomer, Regan had unfettered access to Plaintiff, to the illicit
relationship with Plaintiff, and to carry out, and did carry out all the aforesaid unlawful
and atrocious behaviors as to Plaintiff.
93. By reason of the foregoing, Defendants are liable for violations of Title IX,
ZOUSC Section 1681, et seq, as to the sexual harassment, sexual assault, sexual battery,
and sexual abuse of Plaintiff, in that at all times herein Defendants were responsible for
and liable for the acts of their agents and employees including Defendant Regan, in the
course of their employment.
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AS FOR A SIXTH CAUSE OF ACTION:
CIVIL RIGHTS VIOLATION OF 42 USC §1983
94. Plaintiff repeats 1 —' 83 herein.

paragraphs
95. At all times, Defendants individually and collectively as state actors, had the
authority and positive duty to protect students, including Plaintiff, in their rights,
privileges and immunities as to their lives, liberties and properties, from all harm,
including harm inflicted by Defendant Regan and by the deliberate indifference and
reckless indifference exercised by Defendants themselves, as aforesaid.
96. At all times, Defendants individually and collectively, including Defendant Regan
in his capacity as H.S. Principal, unlawfully deprived Plaintiff of her right to liberty and
to privacy, and including her right to her welfare, dignity and bodily integrity and as to
her electronic property, and as to a free and appropriate public school education, free of
sexual harassment, abuse, assault, and battery.
97. At all times, plaintiffs aforesaid rights were violated in that Plaintiff was
repeatedly deprived of her liberty and property by Defendants in Defendant Regan’s
office as aforesaid, and deprived of her liberty in being required by Defendant Regan to
be present in and out of school with him, and to devote herself to engaging in numerous
texts communications from Defendant Regan, and being caused by Defendants to erase
electronic information and Videos and photos from her cellphone, and by being subjected
to Defendant Regan’s aforesaid sexual grooming, sexual harassment, sexual abuse,
sexual assault and sexual battery, and engage in the improper unlawful erasure and
destruction of Plaintiff’s electronic property and evidence.
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Plaintiff has suffered deprivation of property, intimidation, apprehension, foreboding of

harm, panic, depression, physical and emotional damage, invasion of her privacy,
humiliation, degradation and loss of dignity, all to her damages in a sum to be determined
by the trier of fact.
AS FOR A SEVENTH CAUSE OF ACTION:

INTENTIONAL INFLICTION OF EXTREME EMOTIONAL DISTRESS
99. By reason of the foregoing, in his capacity as H.S. Principal, including but not
limited to Defendant Regan’s persistently atrocious sexual texting, depriving Plaintiff of
the school’s proper counseling, isolating Plaintiff, sending perverse photos and videos to
Plaintiff, threatening Plaintiff and those persons associated with Plaintiff, posturing that
Defendant Regan would physically eliminate his infant daughter, removing Plaintiff’s
sister from Plaintiff by causing Plaintiff’ s sister to attend school in Sagamore, persistently
causing Plaintiff to enter and remain in Defendants’ Principal’s office while the windows
of the doors therein were shielded from scrutiny, in order to carry out Defendant Regan’s
perverse purposes, co-opting Plaintiffs time day and night during school hours and non—
school hours, encouraging Plaintiff to masturbate and engage in perverse sex and View
pornography, then sexually abusing, assaulting and battering Plaintiff in his office, and
then using Plaintiff to assist him in covering up and lying about his aforesaid behaviors
and destroying evidence thereof, Defendant Regan engaged in intentional infliction upon
Plaintiff of extreme emotional distress.
24
100. By reason of the foregoing, Defendants are liable for the intentional infliction
upon Plaintiff of extreme emotional distress in that at all times herein Defendants were
responsible for and liable for the acts of their agents and employees including Defendant
Regan, in the course of their employment.
AS FOR AN EIGHTH CAUSE OF ACTION:

PRIZWA FACIE TORT
sister from Plaintiff by causing Plaintiff’s sister to attend school in Sagamore, persistently
perverse purposes, co—opting Plaintiff’s time day and night during school hours and non-
25
and destroying evidence thereof, Defendant Regan engaged in prima facie tort against
Plaintiff.
103. By reason of the foregoing, Defendants are liable for engaging in a prima facie
tort against Plaintiff in that at all times herein Defendants were responsible for and liable
for the acts of their agents and employees including Defendant Regan, in the course of
their employment.
AS FOR A NINTH CAUSE OF ACTION:

BREACH OF FIDUCIARY DUTIES
105. At all times herein, Defendants stood in loco parentis to Plaintiff, a student in
Defendants’ high school. Thereby, Defendants were fiduciaries of Plaintiff.
106. At all times herein, Defendants were fiduciaries in fact and by law of Plaintiff as
to the proper education of Plaintiff, the physical and mental protection of Plaintiff from
harm, the physical and mental well~being and health of Plaintiff, and the inculcation of
moral, intellectual, ethical principles and good citizenship of Plaintiff.
107. By reason of the foregoing, Defendants enabled Regan, and neglected to prevent
Defendant Regan from, engaging against Plaintiff in the foregoing behaviors.
26
sister from Plaintiff by causing Plaintiff’s sister to attend school in Sagamore, persistently
perverse purposes, co—opting Plaintiffs time day and night during school hours and non-
and destroying evidence thereof, Defendants breached their fiduciary duties as to
Plaintiff.
AS FOR A TENTH CAUSE OF ACTION:

COUNSELING AND PSYCHOLOGICAL MALFEASANCE
110. At all times herein, Plaintiff was in dire need of professional counseling and
psychologist treatment as to Plaintiff’s mental state of depression, and Plaintiffs misuse
of and dependence upon marijuana and alcohol.
27
111. At all times herein, Defendants, their agents and employees knew and should have
known of Plaintiffs aforesaid dire need for professional counseling and psychological
treatment.
112. Accordingly, in or about January 2019 through April 2019, Defendants, their
agents and employees positively undertook to provide such professional counseling and
psychological counseling of Plaintiff by providing Plaintiff with a professional counselor,
and providing Plaintiff in January 2019 with the counseling and psychological service of
HS. Principal, Defendant Regan.
113. At no time did Defendant Regan possess the credentials nor training to provide
professional counseling nor psychological services to Plaintiff.
114. At no time was Defendant Regan qualified to provide professional counseling nor
psychological services to Plaintiff.
115. In and after January 2019, Defendants irrationally, wrongly, and arbitrarily and
capriciously withdrew and/or allowed to lapse, the professional counseling Defendants
had provided to Plaintiff, and instead allowed Defendant Regan at Regan’s urging to
solely continue to provide counseling and psychological services to Plaintiff.
116. Defendants’ professional counseling and psychological services to Plaintiff via
Defendant Regan exclusively consisted of Regan’s sexual grooming of Plaintiff for
Regan’s sexual perverse purposes, in his capacity as H.S. Principal, including but not
Defendant Regan would physically eliminate his infant daughter, removing Plaintiffs
28
sister from Plaintiff by causing Plaintiff‘s sister to attend school in Sagamore, persistently
causing Plaintiff to enter and remain in Defendants” Principal’s office while the windows
perverse purposes, co-opting Plaintiff s time day and night during school hours and non-
school hours, encouraging Plaintiff to masturbate and engage in perverse sex and view
then using Plaintiff to assist him in covering up and lying about his aforesaid behaviors.
117. Defendants’ aforesaid provision of such alleged professional services to Plaintiff
was grossly neglectful, deficient, unprofessional and harmful to Plaintiff.
118. By reason of the foregoing, Defendants engaged in counseling and psychological
malfeasance as to Plaintiff, all to Plaintiff’s harm.
AS FOR AN ELEVENTH CAUSE OF ACTION:

FRAUD
120. Plaintiff repeats allegations in paragraphs 1 —
62 herein.
121. In pretending to professionally counsel and provide psychological services to
Plaintiff, Defendant Regan repeatedly text messaged Plaintiff from January 2019 through
April 29, 2019. Defendant Regan repeatedly fraudulently held out to Plaintiff therein that
his words were intended to professionally counsel and provide psychological services to
29
Plaintiff, whereas the said words were intended to sexually pervert Plaintiff and enable
Defendant Regan to sexually abuse, assault and batter Plaintiff.
122. The texts of Defendant Regan from January 2019 through April 29, 2019
constitute the fraudulent words communicated by Defendant Regan to Plaintiff, attached
as Schedule 1.
123. Plaintiff relied to her detriment upon said fraudulent words in entering into and
continuing the said purported, professional counseling and psychological services
provided by Defendants.
124. By reason of the foregoing, Defendant Regan defrauded Plaintiff.
125. By reason of the foregoing, Defendants defrauded Plaintiff in that at all times
herein Defendants were responsible for and liable for the acts of their agents and
employees including Defendant Regan, in the course of their employment.
AS FOR A TWELTH CAUSE OF ACTION:

FRAUD IN THE INDUCEMENT
127. Plaintiff repeats allegations in paragraphs 1-62 herein.
128. In or about January 2019 through April 29, 2019, Defendant Regan repeatedly
fraudulently induced Plaintiff to accept Regan as Plaintiff’s only counsellor and to
discontinue other counselors, and implied to Plaintiff in text messages that a) Plaintiff
30
should use, and rely solely upon Defendant Regan’s expertise in providing Plaintiff
professional counselling services and psychological services, when in fact Defendant
Regan had no such expertise and instead intended that Plaintiff be fraudulently induced to
accept his services and rely thereon in order that Defendant Regan could sexually pervert
Plaintiff and enable Regan to sexually abuse, assault, and batter Plaintiff; and b) Plaintiff
should give up the professional counselors provided to Plaintiff and instead rely solely
upon the purported services provided by Regan to Plaintiff, when in fact Regan intended
that Plaintiff be fraudulently induced to accept solely his services and rely solely thereon
in order that Defendant Regan could sexually pervert Plaintiff and enable Regan to
sexually abuse, assault and batter Plaintiff without any scrutiny by or interference by the
other professional counselors provided to Plaintiff.
129. Plaintiff relied to her detriment upon said fraudulent words in entering into and
continuing the said purported, professional counseling and psychological services of
Defendant Regan provided by Defendants.
130. By reason of the foregoing, Defendant Regan fraudulently induced Plaintiff to
rely upon Regan’s aforesaid representations so that Plaintiff would erroneously not use or
rely upon the professional counselors provided to Plaintiff, and would instead rely upon
the control and advices of Regan which were intended to sexually pervert Plaintiff and
enable Regan to sexually abuse, assault and batter Plaintiff.
131. By reason of the foregoing, Defendant fraudulently induced Plaintiff as aforesaid
in that at all times herein Defendants were responsible for and liable for the acts of their
31
132. By reason of the forgoing, Plaintiff has been damaged by Defendants in that
AS FOR A THIRTEENTH CAUSEOF ACTION:

GROSSLY NEGLIGENT SUPERVISION
133. At all times herein, Defendants had a duty to supervise the actions of Defendants’
agents and employees, including Defendant Regan and those employees who were aware
of or should have been aware of Defendant Regan’s actions and communications
aforesaid, in relation to Plaintiff.
134. Such supervision included but was not limited to a) Regan’s inordinate time spent
in his office with Plaintiff; b) Regan’s behavior in his office with Plaintiff; c) Regan’s
extraordinary time spent texting with Plaintiff; d) Regan’s text messages to and from
Plaintiff; e) Regan’s use of Defendants” cell phone and of Defendants’ landline phone,
and of Regan’s personal phone, the use of which Defendants contributed payment
thereof; f) Regan’s manipulation and alteration of Plaintiffs attendance records, and
performing Plaintiff’ s homework and persuading Plaintiff to submit the said homework
to her teachers as her own; g) Regan’s walking Plaintiff to Plaintiff” 5 vehicle nearly every
day at the end of the school day.
135. Defendants neglected andgrossly neglected to so supervise Defendant Regan and
Defendants’ agents and employees.
32
136. Said neglect and gross neglect by Defendants resulted in the attempted sexual
perversion of Plaintiff by Regan, the sexual abuse of Plaintiff and sexual assault and
battery upon Plaintiff by Regan, and the other aforesaid harms to Plaintiff.
137. By reason thereof, Plaintiff has been damaged by Defendants in that Plaintiff has
suffered intimidation, apprehension, foreboding of harm, panic, depression, physical and
emotional damage, invasion of her privacy, humiliation, degradation and loss of dignity,
all to her damages in a sum to be determined by the trier of fact.
AS FOR A FOURTEENTH CAUSE OF ACTION:

NEGLIGENT HIRING AND RETENTION
138. Upon information and belief, Defendants had at all times since at least 2000, a
duty to hire and retain a principled role model school administrator with proper
credentials, certifications, experience, history and moral and ethical standards and
disposition, and who was not a sexual pervert and sexual predator.
139. Upon information and belief, at all times since 2000, Defendants had a duty of
investigation, inquiry and research as to all applicants when seeking to employ and when
employing and continuing to employ such administrator.
140. Upon information and belief, Defendant Regan was negligently and recklessly
employed as Assistant Principal by Defendants or Defendants’ predecessors, in or about
June 2006.
141. Upon information and belief, Charles Regan was hired on June 26, 2006 as an
“Emergency 20-day Conditional Appointment,” and that at that time of his hiring,
33
Charles Regan’s resume and level of expertise was neither seen by, nor known by, at
least one member on the Board of Education for Riverhead Central School District.
142. Upon information and belief, at least one member of the Board of Education for
Riverhead Central School District was unable and prevented from making a proper, well-
informed decision as to the hiring of Charles Regan.
143. Upon information and belief, Charles Regan’s “Emergency 20-day Conditional
Appointment” was reapproved and extended on at least two separate occasions: the first
extension having been reapproved on July 11, 2006, with an amendment then passing and
made to make Charles Regan’s appointment a Probationary appointment from July 1,
2006 to June 30, 2009; the second extension having been reapproved on July 25, 2006.
144. Defendants knew or should have known that a) Defendant Regan was not
qualified for the aforesaid position; b) there was in fact no such “emergency” which
required that Defendant Regan be hired without proper credentials or vetting; c) the
Defendant District, its agents and employees were knowingly willfully and/or with
reckless disregard for the State’s requirements for “emergency” hiring of an administrator
and for the welfare of the District’s students, misrepresenting to the state and the public
that there was an “emergency” requiring that Regan be so hired.
145. Defendants knowingly, willfully and recklessly hired Defendant Regan
notwithstanding that he was unqualified for employment with the Defendant District,
thereby inserting sexual predator Regan into a position of authority, to wreak sexual
havoc upon Plaintiff.
146. In or about the school year 2013-2014, Defendants negligently, grossly
negligently and recklessly promoted Defendant Regan to employment as High School
34
Principal of Riverhead Central School District, and kept Regan in that position to the
present, when Defendants knew or should have known that Defendant Regan was
unqualified for that position and was a sexual predator, preying upon students including
Plaintiff.
147. From June 2006 to the present, Defendant was negligently retained in
employment as assistant principal and promoted to High School Principal by Defendants
and Defendants’ predecessors.
148. Defendants or Defendants’ predecessors negligently employed Defendant Regan
when Defendants and their predecessors knew and should have known that Defendant
Regan lacked the requisite New York State Certification for the administrative position.
149. Defendants or Defendants’ predecessors engaged in a false and fraudulent
representation in writing to New York State and the public, that there existed an
“emergency” requiring the Defendants or Defendants’ predecessors to employ Defendant
Regan as assistant Principal, in order to enable Defendants or their predecessors to hire
Defendant Regan although Regan lacked proper certification for said position, when in
fact upon information and belief, no such true emergency existed.
150. At all times, upon information and belief, Defendants knew or should have known
that Defendant Regan had been previously accused of engaging in, and did engage in
improper personal and sexual relationships with female students in his previous
employment as a Special Education teacher and girls basketball coach in the South
Manor Schools and Eastport/South Manor Schools and upon information and belief, in
his previous employment with B.O.C.E.S.
35
;
f'u/ pm 1),;
151. Nonetheless, Without engaging in a full, proper investigation, inquiry and research
to Defendant Regan, and without properly taking into

as account Regan’s employment
history, credentials, experience, history, and moral and ethical standards and disposition,
Defendants and their predecessors, recklessly, negligently and grossly negligently
employed and promoted Defendant Regan as aforesaid, and continued him in his
employment to the present.
152. By reason of the said employment, promotion and continuing employment of
Defendant Regan, Defendants enabled sexual predator and sexual pervert Regan to
sexually groom Plaintiff for Regan’s aforesaid sexual depredations and to engage in said
sexual depredations as to Plaintiff, all to Plaintiffs harm and damages as aforesaid.
153. By reason of the foregoing, Defendants are responsible for and liable for the
negligent and grossly negligent employment, promotion and retention of Regan.
155. For each and every aforesaid cause of action, Plaintiff is entitled to punitive
damages, attorneys’ fees, costs and disbursement in a sum to be determined by the trier of
fact.
WHEREFORE, Plaintiff prays for judgement as follows:
a) On the first cause of action for Sexual Assault, for damages, punitive damages and
attorneys’ fees, costs, and disbursements, in a sum to be determined by the trier of fact.
36
19) On the second cause of action for Sexual Battery, for damages, punitive damages and
attorneys’ fees, costs, and disbursements, in a sum to be determined by the trier of fact.
On the third cause of action for Sexual Abuse, for damages, punitive damages and
attorneys’ fees, costs and disbursements, in a sum to be determined by the trier of fact.
d) On the fourth cause of action for Sexual Harassment, for damages, punitive damages and
On the fifth of action for Violation of Title IX, 20USC§1681 for

cause et seq., damages,
punitive damages and attorneys’ fees, costs and disbursements, in a sum to be determined
On the sixth cause of action for Civil Rights Violation of 42USC§1983, for damages,
punitive damages and attorneys’ fees, costs and disbursements, in a sum to be determined
g) On the seventh cause of action for Intentional Infliction of Extreme Emotional Distress,
for damages, punitive damages and attorneys’ fees, costs and disbursements, in a sum to
be determined by the trier of fact.
h) On the eighth cause of action for Prima Facie Tort for damages, punitive damages and
On the ninth cause of action for Breach of Fiduciary Duties, for damages, punitive
damages and attorneys’ fees, costs and disbursements, in a sum to be determined by the
trier of fact.
j) On the tenth cause of action for Professional Counseling and Psychological Malfeasance,
for damages, punitive damages and attorneys’ fees, costs and disbursements, in a sum to
be determined by the trier of fact.
37
k) On the eleventh cause of action for Fraud, for damages, punitive damages and attorneys’
fees, costs and disbursements, in a sum to be determined by the trier of fact.
1) On the twelfth cause of action for Fraud In the lnducement, for damages, punitive
damages and attorneys’ fees, costs and disbursements, in a sum to be determined by the
trier of fact.
m) On the thirteenth cause of action for Negligent and Grossly Negligent Supervision, for
and attorneys” fees, costs and disbursements, in to be

damages, punitive damages a sum
determined by the trier of fact.
n) On the fourteenth cause of action for Negligent Hiring and Retention, for damages,
punitive damages and attorneys” fees, costs and disbursements, in a sum to be determined
by the trier of fact, and for any other just and proper relief.
Dated: August 5, 2019

Miller Place, New York
Ray, Mmes, LLP

Attorney(s) for Plaintifl
122 North Country Road
P. O. Box 5440
Miller Place, NY 11764
(631) 473-1000
john@raymitevlaw.com
38
VERIFICATION
STATE OF NEW YORK )

) ss.:
COUNTY OF SUFFOLK )
ANASTASIA STAPON, being duly sworn, deposes and says:
She is the Plaintiff in the within action; she has read and knows the contents of the
foregoing Complaint and the same is true to her own knowledge, except as to the matters therein
stated to be alleged upon information and belief, and that as to those matters she believes it to be
/%@:> ANASTASIA STAP
Sworn to before 6 this

5“ day of ,2019
W
Notary Fflbli/é/
V
NOTARY
JOHN RAY ‘1‘.
Pusuc-smfis" OF NEW
No.
{0w
O2RA4786739 I
Q untitled
In Suffolk Co
My unty
Gemmmlon Expires
May 3!.
mafia?»
3‘?
Case 2:19-cv-04708-WFK-ST Document 1-3 Filed 08/15/19 Page 1 of 201 PageID #: 297

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK

RIVERHEAD CENTRAL SCHOOL DISTRICT, VERIFIED COMPLAINT

Plaintiff, ANASTASIA STAPON, by her attorneys, Ray,‘Mitev & Associates, LLP,

appears and complains as follows:

County, New York.

as a high school in the Riverhead Central School District.

Riverhead Central School District.

5. In the school year 2018-2019, Defendant Aurelia L. Henriquez was and is

Superintendent of Riverhead Central School District.

6. Upon information and belief, at all relevant times, Defendant Aurelia L.

Henriquez was and is a resident of Suffolk County, New York.

Board of Education for Riverhead Central School District.

was and is a resident of Suffolk County, New York.

the Board of Education for Riverhead Central School District.

was and is a resident of Suffolk County, New York.

Board of Education for Riverhead Central School District.

and is a resident of Suffolk County, New York.

Board of Education for Riverhead Central School District.

and is a resident of Suffolk County, New York.

Board of Education for Riverhead Central School District.

was and is a resident of Suffolk County, New York.

Board of Education for Riverhead Central School District.

was and is a resident of Suffolk County, New York.

Board of Education for Riverhead Central School District.

and is a resident of Suffolk County, New York.

Riverhead High School.

Riverhead High School in or about June 2006.

for Riverhead Central School District.

24. Upon information and belief, Charles Regan’s employment as an agent or

employee of Riverhead Central School District was approved by the Superintendent of

25. Upon information and belief, Charles Regan’s employment as an agent or

resident of Suffolk County.

Superintendent of Riverhead Central School District.

and is a resident of Suffolk County, New York.

was and is a resident of Suffolk County, New York.

and is a resident of Suffolk County, New York.

McCaffrey was Principal of Riverhead High School.

was and is a resident of Suffolk County, New York.

and is a resident of Suffolk County, New York.

was and is a resident of Suffolk County, New York.

and is a resident of Suffolk County, New York.

was and is a resident of Suffolk County, New York.

and is a resident of Suffolk County, New York.

was and is a resident of Suffolk County, New York.

and is a resident of Suffolk County, New York.

Suffolk County, New York.

Riverhead High School.

20 USC §168l et seq. (Title IX), and 42 USC §1983.

when these acts arose and occurred.

employment as the Principal of Riverhead High School.

harass, sexually seduce, assault, batter, and sexually abuse Plaintiff.

during and after school

and by Defendant District.

Plaintiffs use of marijuana and alcohol in and out of school.

serving as the school principal.

teacher and “Dean” at B.O.C.E.S.

assault, battery, and abuse.

grooming tactics and purposes that Defendant Regan would:

b. Cause Plaintiff to become substantially and entirely dependent upon

Regan in Regan’s authoritative and official position, as a person in place of her

and with her use of marijuana and alcohol;

performed Plaintiffs homework for Plaintiff, to be falsely submitted to teachers