`NYSCEF DOC. NO. 12
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`INDEX NO. EF2020-08421
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`RECEIVED NYSCEF: 09/06/2023
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`1520 Crescent Road, Suite 100 | Clifton Park, NY 12065-7809
`Phone: (518) 373-9900 | Fax: (518) 383-7162
`inquire@millslawny.com | www.millslawny.com
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`PATRICK J. CHAMPAGNE, Paralegal
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`GREGORY S. MILLS, ESQ.
`CHRISTOPHER K. MILLS, ESQ.
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`MICHELLE M. KULAK, ESQ.
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`Hon. Thomas Buchanan
`Schenectady County Supreme Court
`County Judicial Building
`612 State St., 2nd Floor
`Schenectady, New York 12305
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`September 6, 2023
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`Re: Chambers v. Broadalbin-Perth Central
`School District
`Index No.: 202008421
`Our File: 800-2295
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`Dear Justice Buchanan:
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`Pursuant to your directive I am writing to provide a brief status update with regard to
`Chambers v. Broadalbin-Perth Central School District.
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`Plaintiff alleges that he was sexually assaulted and abused by teacher Elizabeth Munn
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`during the end of his 8th grade year through the summer and the beginning of his 9th grade
`year. Plaintiff alleges that the abuse took place on and off school grounds. Plaintiff’s
`Complaint asserts causes of action of negligent supervision and monitoring in addition to
`negligent hiring and retention. The deposition of the Plaintiff has been completed and we are
`in the process of scheduling the deposition of a representative from the School District. It is the
`position of the Defendants that there was no notice to the School District of the alleged conduct
`of the teacher and that all appropriate actions and inquiries were made at the time of the hiring
`and evaluation of the accused teacher. There has been no settlement discussion and, to our
`knowledge, no settlement demand made to date. If a demand is made, we will assess whether
`mediation is a viable option.
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`FILED: FULTON COUNTY CLERK 09/06/2023 05:05 PM
`NYSCEF DOC. NO. 12
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`INDEX NO. EF2020-08421
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`RECEIVED NYSCEF: 09/06/2023
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`If you have any questions in this regard, please do not hesitate to contact our office at
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`your convenience.
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`BY:
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`MICHELLE M. KULAK
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`Very truly yours,
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`THE MILLS LAW FIRM, LLP
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