Motion for Child Visitation in Js, An Infant Under The Age Of 14 Years, By Her Father And Natural Guardian Amidou Samassi, Amidou Samassi, Individually v. Thrillz, Llc., Harlem Children'S Zone, Inc., Promise Academy Ii Middle School, New York City Department Of Education, New York City Board Of Education, City Of New York| Trellis.Law

On December 31, 2019 a Motion-Secondary was filed involving a dispute between Amidou Samassi, Individually, Js, An Infant Under The Age Of 14 Years, By Her Father And Natural Guardian Amidou Samassi, and City Of New York, Harlem Children'S Zone, Inc., New York City Board Of Education, New York City Department Of Education, Promise Academy Ii Middle School, Thrillz, Llc., for Torts - Other (PREMISES) in the District Court of New York County.

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
——————————————————————X
JS, an infant under the age of 14 years, by her father and Index No.: 162580/19
natural guardian AMIDOU SAMASSI and AMIDOU
SAMASSI, individually,

Plaintiffs, REPLY AFFIRMATION
TO THE OPPOSITION OF
-against- DEFENDANTS HARLEM
CHILDREN'S ZONE, INC. AND
THRILLZ LLC, HARLEM CHILDREN'S ZONE, INC., PROMISE ACADEMY II
PROMISE ACADEMY II MIDDLE SCHOOL, NEW MIDDLE SCHOOL
YORK CITY DEPARTMENT OF EDUCATION,
NEW YORK CITY BOARD OF EDUCATION and
CITY OF NEW YORK,

Defendants.
——————————————————————X
LISA R. KRAMER, an attorney duly admitted to practice law in the Courts of the State

of New York, under penalties of perjury, affirms as follows:

1. I am a partner with the law firm of GOETZ SCHENKER BLEE &

WIEDERHORN, L.L.P., attorneys for the Defendant, THRILLZ LLC, in the above-entitled

action. As such, I am fully familiar with the facts and circumstances of the proceedings had

herein.

2. This Affirmation is submitted in further support of the Defendant’s motion for an

Order, pursuant to CPLR §3211(a)(8), CPLR §301, and CPLR §302(a), dismissing the Plaintiff’s

Complaint and all cross-claims, in their entirety on the grounds that this Court does not have

jurisdiction over Defendant, THRILLZ LLC, together with such other and further relief as the

Court deems just and proper. This Affirmation is also submitted in response to the opposition of

defendants, HARLEM CHILDREN'S ZONE, INC. and PROMISE ACADEMY II MIDDLE

SCHOOL (hereinafter referred to collectively as “HARLEM”).

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3. The contentions of Defendants, HARLEM, are unsupported by admissible

documents and therefore are insufficient to defeat the instant motion to dismiss plaintiff’s

complaint and all cross-claims.

4. Counsel for Defendants, HARLEM, have failed to submit admissible proof, such

as an affidavit by a person having personal knowledge of the facts. The affirmation of an

attorney which is not based upon personal knowledge of the facts is of no probative or

evidentiary significance, and will not suffice to defeat a motion to dismiss the complaint and all

cross claims. See, Currie v Wilhouski, 93 A.D.3d 816, 941 N.Y.S.2d 218 (2nd Dept., 2012);

Cullin v Spiess, 122 A.D.3d 792 (2nd Dept., 2014); US National Bank Association v Melton, 90

A.D.3d 742, 934 N.Y.S.2d 352 (2nd Dept., 2011); Warrington v. Ryder Truck Rental, 35 A.D.3d

455; 826 N.Y.S.2d 152 (2nd Dept., 2006); JMD Holding Corp. v. Congress Financial Corp., 4

N.Y.3d 373, 828 N.E.2d 604, 795 N.Y.S.2d 502 (2005). Defendants, HARLEM, failed to submit

any proof in admissible form raising an issue of fact that this Court has jurisdiction over

defendant, THRILLZ LLC.

5. Defendants, HARLEM, make reference to emails between THRILLZ LLC and

HARLEM in a feigned attempt to defeat the instant motion. However, coincidentally, no such

emails were annexed to HARLEM’s opposition papers. There is no evidence whatsoever that

the parties contracted in New York or that THRILLZ, LLC conducted any business in New

York. The case law is clear that said unsupported arguments are insufficient to defeat THRILLZ

LLC’s pre-answer motion to dismiss, as the contentions of an attorney with no personal

knowledge of the facts is of no probative value. See, Currie, supra; Cullin, supra; US National

Bank Association, supra; Warrington, supra; MD Holding Corp., supra.

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6. Defendants, HARLEM, annexed receipts to show transactions and purchase

orders between the parties (see, Exhibit “B” and Exhibit “C” annexed to HARLEM’s

opposition). However, the documents are unsworn, uncertified and inadmissible to defeat the

instant motion. There is no affidavit from HARLEM to authenticate the admissibility of the

documents. There are foundation requirements to qualify a document as a business record, of

which defendants, HARLEM, have not complied. See, Midisland Medical, PLLC v. Allstate

Insurance Company, 867 N.Y.S.2d 376 (2nd Dept., 2008). There is a "strict requirement" that

"evidentiary proof in admissible form" be submitted. See, Friends of Animals, Inc. v. Associated

Fur Manufacturers, Inc., 46 N.Y.2d 1065, 390 N.E.2d 298, 416 N.Y.S.2d 790 (1979);

Zuckerman v. City of New York, 49 N.Y.2d 557, 404 N.E.2d 718, 427 N.Y.S.2d 595 (1980);

Pagano v. Kingsbury, 182 A.D.2d 268, 587 N.Y.S.2d 692 (2nd Dept., 1992); Williams v. Hughes,

256 A.D.2d 461, 682 N.Y.S.2d 401 (2nd Dept., 1998) Clemmer v Drah Cab Corp., 74 A.D.3d

660, 905 N.Y.S.2d 31 (1st Dept., 2010). The receipts and purchase orders are unauthenticated,

uncertified and inadmissible, and constitute “incompetent and inadmissible hearsay”. See, Perez

v. Brux Cab Corp., 251 A.D.2d 157, 674 N.Y.S.2d 343 (1st Dept., 1998) Holliday v. Hudson

Armored Car & Courier Serv., 301 A.D.2d 392, 753 N.Y.S.2d 470 (1st Dept., 2003); Shehab v

Powers, 150 A.D.3d 918, 54 N.Y.S.3d 104, (2nd Dept., 2017).

7. Moreover, even if the Court were to consider said records as admissible, which is

vehemently objected to by Defendant, these receipts and purchase orders are insufficient to

establish that THRILLZ LLC contracted with HARLEM in New York. There is no evidence

whatsoever that there was an interstate transaction occurred. HARLEM having been given a

receipt is not indicative of any transaction occurring in the state of New York. Additionally, the

fact that HARLEM admittedly created its own purchase orders is not indicative of any

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transaction occurring between the parties in New York. Rather, HARLEM created the purchase

order in New York. THRILLZ did not generate the purchase order and there is no indication that

any transaction between the parties occurred in New York. HARLEM failed to establish that any

of negotiations and/or transactions between the parties occurred in New York. See, Leiderman

Assoc. v. Robotool, Ltd., 546 N.Y.S.2d 137, 154 A.D.2d 515 (2nd Dept., 1989); There is no

evidence that THRILLZ LLC conducted any transactions with HARLEM, or any of the other

parties in the state of New York. HARLEM failed to raise an issue of fact to establish

jurisdiction in New York State courts over THRILLZ LLC.

8. While HARLEM failed to establish any ongoing meetings or negotiations

between the parties within the state of New York, it should be noted that “[n]ot all contract

negotiations amount to the transaction of business within the State”. Taberna Preferred Funding

II, Ltd. v Advance Realty Group LLC, 45 Misc. 3d 1204(A), 5 N.Y.S.3d 330 (NY County,

2014); Leiderman Assoc., supra; Presidential Realty Corp. v. Michael Square West, Ltd., 44

N.Y.2d 672, 376 N.E.2d 198, 405 N.Y.S.2d 37 (1978) [New York meetings insufficient to

establish jurisdiction where there was no evidence as to substance of meetings]; Physical

presence alone cannot talismanically transform any and all business dealings into business

transactions under N.Y. C.P.L.R. 302(a)(1). Presidential Realty Corp., supra.

9. In Presidential Realty Corp., supra, the Court of Appeals held that

Jurisdiction, if any, under New York's long-arm statute would appear in
this instance to turn on the extent of defendants' activities in New York
State …. No reliance can be placed on any attendant negotiations on that
day since no proof is tendered by one having personal knowledge either of
the fact or the extent of any negotiations. Therefore on the record before
us there is no proof of any contacts with this State other than the fact that
the modification letter and the agreement were signed in New York. This
is not sufficient to confer jurisdiction.

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Id at 673-674. In the instant case, Defendants, HARLEM, have failed to establish any contacts

THRILLZ had within the state of New York, whether there were multiple negotiations, or a

single meeting, or any actual contacts within the State of New York. As in Presidential Realty

Corp., supra, HARLEM failed to submit any proof by one having personal knowledge either of

the fact or the extent of any negotiations. See also, Abbate v. Abbate, 82 A.D.2d 368, 441

N.Y.S.2d 506, (2nd Dept., 1981) [the "purely ministerial" act of merely executing a contract in

New York that had been negotiated elsewhere, would likely be insufficient to confer personal

jurisdiction.” There is no evidence that any agreement between the parties was negotiated in

New York. The purchase order generated by HARLEM is insufficient to establish any contacts

within the state of New York.

10. “Further, “an essential criterion in all cases is whether the 'quality and nature' of

the defendant's activity is such that it is 'reasonable' and 'fair' to require him to conduct his

defense in that State" Riblet Prods. Corp. v. Nagy, 595 N.Y.S.2d 228, 191 A.D.2d 626 (2nd

Dept, 1993), citing, Kulko v. Superior Court of Cal., 436 U.S. 84, 98 S. Ct. 1690 (U.S.S.C.,

1978), quoting from Int'l Shoe Co. v. Wash., 326 U.S. 310, 66 S. Ct. 154 (U.S.S.C., 1945).

Defendants, HARLEM, have submitted no admissible evidence of the quality and nature, or any

activity of THRILLZ LLC whatsoever, in the state of New York that would require THRILLZ

LLC to conduct a defense in New York.

11. “For the courts of this State to exercise jurisdiction over a nondomiciliary foreign

corporation, due process requires sufficient ‘minimum contacts’ between the nondomiciliary and

the forum State so that ‘traditional notions of fair play and substantial justice' are not offended.”

Carpino v. National Store Fixtures Inc., 275 A.D.2d 580, 582, 712 N.Y.S.2d 684 (3rd Dept.,

2000), citing, Asahi Metal Indus. Co. v. Superior Court of Cal., 480 U.S. 102, 105, 107 S. Ct.

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1026 (U.S.S.C., 1987), quoting, Int'l Shoe Co., supra, at 316. “A ‘minimum contacts’ finding

requires more than a reasonable expectation that a tortious foreign act will have New York

consequences.” Carpino, supra at 582. “It requires the foreseeability that one's product may

make its way to New York ‘coupled with evidence of a purposeful New York affiliation.’” Id.,

at 582, quoting Schaadt v. T. W. Kutter, Inc., 169 A.D.2d 969, 970, 564 N.Y.S.2d 865 (3rd Dept.,

1991). See, Murdock v. Arenson Int'l USA, Inc., 157 A.D.2d 110, 554 N.Y.S.2d 887 (1st Dept.,

1990). The evidence submitted in this case is devoid of any proof that THRILLZ LLC Conner

acted in such a manner to "'purposefully avail itself of the privilege of conducting activities

within the forum State'" Carpino, supra; quoting, World-Wide Volkswagen Corp. v. Woodson,

444 U.S. 286, 297, 100 S. Ct. 559 (U.S.S.C., 1980), quoting, Hanson v. Denckla, 357 U.S. 235,

253, 78 S. Ct. 1228 (U.S.S.C., 1958). As such, THRILLZ LLC is not subject to the jurisdiction

of New York courts.

12. The purchase order was generated in New York by HARLEM and not by

THRILLZ LLC. There is no evidence the terms of any agreement were negotiated in New York,

nor is there any evidence of any presence of THRILLZ in New York. It is not even shown that

the purchase order was delivered to THRILLZ LLC in New York, although same would be

insufficient to establish jurisdiction over said Defendant. Klein v. E. W. Reynolds Co., 355 F.

Supp. 886 (SDNY, 1973) [the single act of delivering a purchase order in New York is not

sufficient contact with New York to give its courts personal jurisdiction over the defendant.] See

also, McKee Electric Co. v. Rauland-Borg Corp., 20 N.Y.2d 377, 229 N.E.2d 604, 283 N.Y.S.2d

34 (1967). “It is clear that the sending of an order into the state even when it is essential to the

formation of a contract is insufficient to give the New York courts personal jurisdiction. Klein,

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supra at 888; M. Katz & Son Billiard Products, Inc. v. G. Correale & Sons, Inc., 26 A.D.2d 52,

270 N.Y.S.2d 672 (1st Dept., 1966), aff’d 20 N.Y.2d 903, 285 N.Y.S.2d 871 (1967).

13. Defendants, HARLEM, concede that the plaintiff was under its supervision at the

time of the alleged accident. The fact that a New York entity was supervising the plaintiff in

Connecticut does not give rise to sufficient contacts with New York for this Court to maintain

jurisdiction over THRILLZ LLC. The fact remains that this alleged accident occurred in the

State of Connecticut and there has been no admissible evidence to establish sufficient contacts by

THRILLZ LLC in New York to confer jurisdiction.

14. HARLEM relies on uncertified and unsworn “teambuilding posts”, Facebook

posts, Yelp reviews, and Trip Advisor posts in a feigned attempt to argue that THRILLZ LLC

conducts business in New York. These records are inadmissible, as HARLEM has failed to lay

proper foundation to qualify the documents as a business record. See, Midisland Medical, PLLC,

supra; Friends of Animals, Inc. supra; Zuckerman, supra; Pagano, supra; Williams, supra;

Clemmer, supra. The “teambuilding posts”, Facebook posts, Yelp reviews, and Trip Advisor

posts are unauthenticated, uncertified and inadmissible, and constituted “incompetent and

inadmissible hearsay”. See, Perez, supra; Holliday, supra; Shehab, supra. HARLEM has failed

to submit any documentation to authenticate these posts, and as stated above, an attorney’s

affirmation with no personal knowledge is of no probative value.

15. Not only are the “teambuilding posts”, Facebook posts, Yelp reviews, and Trip

Advisor posts inadmissible but they most certainly do not show that “THRILLZ has minimum

contacts with New York, despite HARLEM’s baseless contention. Rather, it simply shows that

another New York company, or New York residents came to Connecticut. There is no evidence

whatsoever that THRILLZ held an event specifically for a New York Company or resident, or

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that it recruited New Yorkers onto its property. Nor is there any evidence in said documents that

THRILLZ LLC contracted with a New York company or resident in New York, or that

THRILLZ LLC advertised or solicited business in New York. There is also no evidence that the

Connecticut company’s website or Facebook page were created, maintained, or operated in New

York. New Yorkers came to Connecticut to participate in Connecticut activities and thus should

be required to be bound by Connecticut courts.

16. In McGowan v. Smith, 52 N.Y.2d 268, 419 N.E.2d 321, 437 N.Y.S.2d 643

(1981), the third-party plaintiff relied upon several visits made to New York for the purpose of

doing general marketing research and ascertaining what type of products might be salable in

New York. The Court of Appeals held that,

[w]hile these visits certainly may be characterized as ‘purposeful’, they
cannot form the predicate for the exercise of in personam jurisdiction
under CPLR 302 (subd [a], par 1) for the simple reason that they have not
been shown to bear a substantial relationship to the transaction out of
which the instant cause of action arose. Absent such a showing, the
occurrence of these visits serves merely to establish Mogi's transitory
physical presence within the State.

Id at 272. Similarly, any conduct of THRILLZ LLC has not been shown to have a substantial

relationship to any transaction with HARLEM or the subject alleged accident.

17. There is no personal jurisdiction over THRILLZ LLC, as said company was

incorporated in the state of Connecticut, and is located in Connecticut (See, Exhibit “B” annexed

to Defendant’s original motion). “THRILLZ LLC does not maintain, and has never maintained,

an office or a place of business in the state of New York” (Id). “THRILLZ LLC does not

transact and/or conduct business in the state of New York… and is not qualified to do business in

the state of New York” (Id). “THRILLZ LLC has no telephone listing, assets, bank accounts or

real property in the state of New York….”, nor does said company have any officers, agents or

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employees in the state of New York” (Id). “THRILLZ LLC does not solicit business in the state

of New York….., does not advertise on any billboards located in the state of New York, does not

mail any literature in the state of New York, and does not have any sales representatives conduct

business in the state of New York” (Id). “The alleged subject accident occurred in Danbury,

Connecticut” and does not “arise out of any contact with the state of New York by THRILLZ

LLC” (id).

18. HARLEM does not provide any admissible evidence of the parties contracting

business within the state of New York. Speculation and surmise is not a basis upon which the

court can base decision with regard to this matter. Martinez v. Te, 75 A.D.3d 1, 901 N.Y.S.2d

161 (1st Dept., 2010); Catlyn v. Hotel & 33 Co., 230 A.D.2d 655, 646 N.Y.S.2d 513 (1st Dept.,

1996); Leggio v. Gearhart, 294 A.D.2d 543, 743 N.Y.S.2d 135 (2nd Dept., 2002); Zuckerman v.

City of New York, 49 N.Y.2d 557, 404 N.E.2d 718 (1980); In re Shapolsky, 8 A.D.2d 122, 185

N.Y.S.2d 639 (1st Dept., 1959). Defendants, HARLEM, must produce admissible evidence to

support their contention that this Court has jurisdiction over defendant, THRILLZ LLC.

Defendants, HARLEM, have produced no contract between THRILLZ LLC and any of the co-

defendants because no such contract exists. As stated in the original motion papers, THRILLZ

LLC does not transact and/or conduct business in the state of New York (see, Exhibit “B”

annexed to Defendant’s original motion papers).

19. Moreover, there is no jurisdiction over defendant, THRILLZ LLC, under CPLR

§302(a)(3) as defendant, THRILLZ LLC, does not solicit business, or regularly conduct or

engage in any other persistent course of conduct in New York (see, Exhibit “B” annexed to

Defendant’s original motion). Defendant does not derive income from New York, as THRILLZ

LLC is located in Connecticut and conducts its business in the state of Connecticut (Id).

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20. “It has consistently been held that mere solicitation of business by a foreign

corporation in New York is an insufficient basis for the exercise of personal jurisdiction.” Grill

v. Walt Disney Co., 683 F. Supp. 66 (S.D.N.Y. April 5, 1988); Rolls-Motors, Inc. v. Charles

Schmitt & Co., 657 F. Supp. 1040, 1044-45 (S.D.N.Y. 1987). Defendants, HARLEM, have

established no contact of THRILLZ LLC in New York.

21. There is also no long arm or in personam jurisdiction over Defendant, THRILLZ

LLC under CPLR §302. It is evident that Defendants, HARLEM, cannot meet their burden

under the long arm statute. Defendant, THRILLZ LLC does not regularly do or solicit business

in New York (see, Exhibit “B” annexed to Defendant’s original motion; §302(a)(3). Defendant,

THRILLZ LLC does not engage in any other persistent course of conduct in New York State

(id). Defendant, THRILLZ LLC does not derive substantial revenue from goods used or

consumed or services rendered in New York State (id). Defendant THRILLZ is located in

Connecticut, and its services are rendered in Connecticut. Defendant does not conduct business

in New York State (id).

22. Defendant, THRILLZ LLC, did not expect or should not have reasonably

expected plaintiff’s participation at Defendant’s facility to have consequences in New York State

(id). Defendant THRILLZ LLC is located in Connecticut, and its services are rendered in

Connecticut. Defendant does not conduct business in New York State (id).

23. There is no personal jurisdiction over THRILLZ LLC, as said company was

incorporated in the state of Connecticut, and is located in Connecticut (See, Exhibit “B” annexed

to Defendant’s original motion). “THRILLZ LLC does not maintain, and has never maintained,

an office or a place of business in the state of New York” (Id). “THRILLZ LLC does not

transact and/or conduct business in the state of New York… and is not qualified to do business in

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the state of New York” (Id). “THRILLZ LLC has no telephone listing, assets, bank accounts or

real property in the state of New York….”, nor does said company have any officers, agents or

employees in the state of New York” (Id). “THRILLZ LLC does not solicit business in the state

of New York….., does not advertise on any billboards located in the state of New York, does not

mail any literature in the state of New York, and does not have any sales representatives conduct

business in the state of New York” (Id). “The alleged subject accident occurred in Danbury,

Connecticut” and does not “arise out of any contact with the state of New York by THRILLZ

LLC” (id).

24. THRILLZ LLC did not engage in a sufficient amount of activities or any activity

to support a finding that it was present in New York. THRILLZ LLC does not have an office or

principal place of business in New York, nor is it incorporated in New York (See, Exhibit “B”

annexed to Defendant’s original motion). THRILLZ LLC does not conduct business in New

York and HARLEM’s allegation regarding same is insufficient to maintain jurisdiction over this

Defendant (id). See, Daimler AG v. Bauman, 134 S Ct. 746, 751 (2014).

25. THRILLZ LLC did not conduct business in New York and did not contract to

supply goods or services in New York (id; CPLR §302(a)(1)). Defendant did not have any

employees travel to New York to solicit the business of the plaintiff or codefendants (id).

Defendant has not performed any purposeful acts to subject itself to the jurisdiction of New York

(Id). The accident which is the subject matter of plaintiff’s lawsuit occurred in Connecticut.

Defendants, HARLEM, have no basis under CPLR §302 for asserting jurisdiction.

26. There are no contacts with New York to establish personal jurisdiction under

CPLR §302(a)(2). THRILLZ LLC is a Connecticut company with its principal place of business

in Connecticut (see, Exhibit “B” annexed to Defendant’s original papers). There is no

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connection between THRILLZ LLC and New York to warrant jurisdiction over this Defendant.

There are no effects of THRILLZ LLC on New York and no effects are pled. THRILLZ LLC

did not commit any tortious act within New York State. Again, the alleged accident which is the

subject matter of plaintiff’s lawsuit occurred in Connecticut.

27. CPLR §302(a)(4) requires a finding that the defendant owns, uses or possesses any

real property situated within the state. THRILLZ LLC does not meet the criteria for jurisdiction

in New York under this provision (see, Exhibit “B” annexed to Defendant’s original motion).

28. Defendants, HARLEM, argue that it has asserted cross-claims against THRILLZ

and thus there is jurisdiction over THRILLZ LLC in New York with regard to said cross-claims.

Said argument is unsupported and nonsensical. If plaintiff’s cause of action cannot be sustained

against THRILLZ LLC in New York, then the complaint against said defendant must be

dismissed and the cross-claims by co-defendants, including those of HARLEM are improper and

cannot survive in New York. This is basic civil procedure.

29. HARLEM has provided no admissible evidence of valid cross-clam for

indemnification against THRILLZ LLC. There is no contract or other admissible document

submitted by HARLEM whereby THRILLZ LLC owes indemnification to HARLEM. As stated,

the arguments of counsel for HARLEM, which are unsupported by admissible documents and

affidavit of a person with personal knowledge are of no probative value and are insufficient to

defeat the instant motion.

30. Not only did HARLEM fail to submit any admissible evidence to support a cross-

claim for indemnification, but the mere allegation of a claim for indemnification does not give

rise to jurisdiction over THRILLZ LLC by this New York court. The fact remains that any

claims against THRILLZ LLC should have been commenced in Connecticut. The purchase

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orders and receipts, while inadmissible, due not contain indemnification language, and

HARLEM has failed to submit any evidence that THRILLZ LLC agreed to subject itself to the

courts of New York.

31. This action has no connection with the state of New York, other than the

residency of the plaintiffs and the principal place of business of the co-defendants (see, Exhibit

“A” and Exhibit “B” annexed to Defendant’s original motion). Defendants, HARLEM have

submitted no admissible evidence to establish jurisdiction over THRILLZ LLC in the courts in

the state of New York. Moreover, defendants, HARLEM, have failed to establish that a proper

lawsuit against all parties could have been commenced in the state of Connecticut. There is no

basis for jurisdiction by the Courts of the state of New York over THRILLZ LLC.

WHEREFORE, on the basis of the foregoing, Defendant respectfully requests that this

Honorable Court grant the instant motion in its entirety, together with such other and further

relief as to this Court seems just, proper and equitable.

Dated: New York, New York
June 23, 2020

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Case Info

Judge

Lyle E Frank Track Judge’s New Case

Case No.

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Document Filed Date

June 23, 2020

Case Filing Date

December 31, 2019

County

Parties

AMIDOU SAMASSI, individually Plaintiff
BENOIT, ZACHARY RICHARD Attorney for the Defendants
CITY OF NEW YORK Defendant
GRIECO, LISA LYNN Attorney for the Plaintiff
HARLEM CHILDREN'S ZONE, INC. Defendant
JS, an infant under the age of 14 years, by her father and natural guardian AMIDOU SAMASSI Plaintiff
KRAMER, LISA RENEE Attorney for the Defendants
LOFTUS, KEVIN M Attorney for the Defendants
NEW YORK CITY BOARD OF EDUCATION Defendant
NEW YORK CITY DEPARTMENT OF EDUCATION Defendant
PROMISE ACADEMY II MIDDLE SCHOOL Defendant
THRILLZ, LLC. Defendant
DYLAN HELFAND Attorneys for Plaintiffs

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