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`Expert Witness Report
`Elizabeth L. Jeglic Ph.D.
`
`AB 511 Doe v. Lyndonville Central School District; Lyndonville Elementary School
`
`Overview and Purpose:
`
`This report has been prepared at the request of Webster Szanyi LLP law firm who represent the
`defendant Lyndonville Central School District; Lyndonville Elementary School (LCSD/LES) in the above-
`captioned matter. I have been asked to render my professional opinion on items I-IV below. All my
`opinions are rendered to a reasonable degree of certainty based upon the materials reviewed as listed
`below, my expertise as a sexual violence prevention researcher and clinical psychologist, and research,
`legislation, and reports conducted in the field of educator sexual misconduct. Full details of my
`qualifications and experience entitling me to give expert opinion are listed in my curriculum vitae (see
`Attachment 1). As this report and my opinion are based upon information available at the time of
`writing as listed below, I reserve the right to amend this report should additional evidence become
`available.
`
`Materials Reviewed in Formulating my Opinions:
`
`1. Deposition of Plaintiff AB 511 Doe
`2. Deposition of Russell Martino
`3. Deposition of Donald Bow
`4. Deposition of Joseph DiPassio
`5. Deposition of Jason Smith
`6. Deposition of Anthony Figurilli
`7. Deposition of Kathleen Hurtgam
`8. Deposition of Ruth Bane
`9. Deposition of Nancy Townsend
`10. Plaintiff exhibits 1-7; Exhibit 9 and DiPassio Exhibit 1
`11. Plaintiff’s Summons and Complaint
`12. Plaintiff’s Response to Defendant’s First Request for Interrogatories
`13. Defendant’s Response to Interrogatories
`14. Defendant’s Response to Request for Production dated July 20, 2021
`15. Plaintiff’s Expert Disclosure
`16. Trial Transcript from Houseman’s 1990 Criminal matter (District 000001-000200)
`17. Board of Education Appointment (District 000201)
`18. Houseman’s Personnel File (District 000202-000361)
`19. 1990 Complaint against Houseman (District 000363)
`20. 1990 Criminal Investigation regarding Houseman (District 000364-000384)
`21. Record Retention Policy (District 000440-000606)
`22. Russell Martino Personnel File (District 000613-000806)
`23. Donald Bow Personnel File (District 000807-000833)
`24. Lyndonville Teacher Association Agreements from 1981-1991 (District 000834-000945)
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`1
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`25. Board of Education Policy (Student and Personnel) Dev. 1978, Rev 1982 (District 000955-
`001040)
`26. Board of Education Policy (Student and Personnel) 1989 (District 001041-001159)
`27. Board of Education Policies (9-26-1983 BOE meeting) (District 001160)
`28. Child Abuse Policy (10-24-1983 BOE meeting)(District 001161)
`29. Houseman Resignation (District 001162).
`30. My research and expertise in the area of sexual offending behavior, educator sexual misconduct,
`sexual victimization and sexual violence prevention.
`31. Research, legislation, and reports in the field of sexual offending, sexual grooming, and educator
`sexual misconduct (see Attachment 3).
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`Professional Opinions and Basis for those Opinions:
`
`I.
`
`It is my opinion that the sexual abuse perpetrated by those employed in child serving
`organizations such as schools was not well known in the 1980s.
`
`My opinion is based upon the historical research on child sexual abuse. In the 1970s and 80s most
`information about child sexual abuse focused on abuse perpetrated by strangers and family members
`(Lanning, 2018). The wide-spread risk of child sexual abuse by individuals employed in child serving
`organizations such as schools only became known to the public in the 2000s. It was early 2002 when the
`Boston Globe first reported on the widespread scope and cover-up of sexual abuse by priests within the
`Catholic Church. Similarly, allegations of sexual abuse by leaders within the Boy Scouts of America had
`been surfacing for decades, but it was only in 2010 that a judge ordered the release of records showing
`that over 12,000 boys had been abused by 7,800 Scoutmasters between 1944 and 2006. It was only in
`the No Child Left Behind Act of 2001, which amended Section 5414 of the 1965 Elementary and
`Secondary Education Act, that “a national study of sexual abuse in schools” was required. Thus, at the
`behest of the U.S. Department of Education, Charol Shakeshaft was asked to conduct a review of the
`research on educator sexual misconduct to assess the scope of the problem. In Shakeshaft’s 2004
`report to the U.S. Department of Education entitled “Educator Sexual Misconduct: A Synthesis of
`Existing Literature”, colloquially known as the Shakeshaft Report. Relying on results from an expansive
`survey, in the report Shakeshaft stated that while the vast majority of schools in America are safe places,
`the best estimate is that 6.7% of students will experience contact educator sexual misconduct at some
`point in their educational career. Shakeshaft however cautioned that even given that statistic relatively
`little was known about the characteristics and prevalence of educator sexual misconduct and firm
`conclusions could not be drawn as there are few empirical studies on educator sexual misconduct and
`the existing studies has serious methodological limitations. Except for one study which was published in
`1986 broadly examining the link between child molestation and homosexuality and was not focused on
`educator sexual abuse, all other empirical research reviewed in the Shakeshaft Report was published in
`the 1990s and 2000s. In 1979, the U.S. Department of Health and Human Services published “The
`Educator’s Role in the Prevention and Treatment of Child Abuse and Neglect” however that publication
`authored by Broadhurst speaks specifically to the role of educators in identifying abuse perpetrated by
`others outside of the school environment, specifically the child’s parents and guardians, and does not
`address educator sexual misconduct at all.
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`In terms of policies and legislation in New York State, The Child Protective Services Act was enacted in
`1973, but the text of the legislation only applied to abuse perpetrated by a parent or person legally
`responsible for the child and did not address sexual abuse perpetrated by educators. It was only in 1973
`under this Act that school authorities became mandated reporters of child abuse. It was not until the
`passage of New York State Education Law Article 23-B in 2001 that standardized policies and procedures
`for the reporting, investigation and identification of educator sexual misconduct were implemented.
`This was 14 years after AB 511 Doe alleged sexual abuse by Terry Houseman at LCSD/LES.
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`II.
`
`It is my opinion that LCSD/LES officials and employees could not have known that Terry
`Houseman was abusing Plaintiff AB 511 Doe based upon his publicly observable behavior in
`the school or in the community.
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`My opinion is based upon the depositions of former teachers Ruth Bane, Anthony Figurilli, Nancy
`Townsend and Kathleen Hurtgam and former Principal Russell Martino who all worked with Terry
`Houseman at LCSD/LES for multiple years. None of the educators reported witnessing inappropriate
`behavior, hearing rumors of inappropriate behavior or suspecting Terry Houseman of engaging in
`inappropriate behavior with children. All stated in their depositions that if they had seen or suspected
`that Terry Houseman was abusing children that they would have reported it to the principal. Plaintiff AB
`511 Doe reported in his deposition that be believed that Ruth Bane witnessed Terry Houseman sexually
`abusing him in the classroom but in her deposition, Ruth Bane denied that she ever witnessed anything
`and stated that if she had witnessed abuse, she would have reported it immediately.
`
`During the time frame that Terry Houseman was alleged to have perpetrated the sexual abuse on AB
`511 Doe (1986-87), sexual grooming had yet to be identified by researchers and law enforcement and
`thus behaviors which today could be construed as sexual grooming such as putting his arm around
`students were viewed positively by Principal Martino as an indication of a caring teacher. In his
`deposition Plaintiff AB 511 Doe reported that he never told anyone about the abuse, and he does not
`think that the LCSD/LES administrators knew he was being abused at the time.
`
`The research on child sexual grooming only began in the 2000s with theoretical papers and case studies
`(see Craven et al., 2006; McAlinden, 2006). The empirical study of child sexual grooming then started in
`the 2010s (Williams, 2015; Williams & Hudson, 2013; Wolf et al., 2018). However, it was only in 2020
`that Winters and colleges developed and content validated the Sexual Grooming Model (SGM) of child
`sexual grooming in which a list of 42 specific sexual grooming behaviors and tactics employed by those
`who abuse children was empirically derived. Subsequently in 2022 a universal definition of child sexual
`grooming was proposed (Winters et al., 2022) and a measure of child sexual grooming was developed
`(Winters & Jeglic, 2022). Furthermore, the first empirical study identifying “red flag” sexual grooming
`behaviors which identify specific sexual grooming behaviors that are indicative of child sexual abuse and
`differentiate them from normal adult-child interactions was just published in 2023 (Jeglic et al., 2023).
`
`It was not until 2011, when it was revealed that Penn State football coach Jerry Sandusky had been
`abusing minors for over 15 years that the public was introduced the term sexual grooming (Winters &
`Jeglic, 2016). Current research suggests that sexual grooming is subject to a hindsight bias and that
`sexual grooming behaviors are more easily identified retrospectively (i.e., after they know sexual abuse
`has occurred), and even today people may have a difficult time recognizing potentially predatory sexual
`grooming behaviors especially those that
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`do not involve sexual content or touch (Spenard & Cash, 2022; Winters & Jeglic, 2016; 2017). Also, most
`sexual grooming behaviors mirror caring adult-child interactions, and it is only their nefarious intent
`(which is not easily visibly discerned) that determines whether the intent of the behavior or tactic is to
`groom the child for sexual abuse (Winters et al., 2020).
`
`It should also be noted that in a manual prepared by Broadhurst in 1979 for the National Center on Child
`Abuse and Neglect entitled “The Educator’s Role in the Prevention and Treatment of Child Abuse and
`Neglect” she describes the physical and behavioral indicators of child sexual abuse as known at the time
`to include:
`
`Physical Indicators
`• Difficulty in walking/sitting
`• Torn, stained or bloody underclothing
`• Pain or itching in genital area
`• Bruises or bleeding in external genital,
`vaginal or anal areas
`• Venereal diseases, especially in pre-teens
`• Pregnancy
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`Behavioral indicators
`• Unwilling to change for gym or
`participate in physical education class
`• Withdrawal, fantasy or infantile behavior
`• Bizarre, sophisticated or unusual sexual
`behavior or knowledge
`• Poor peer relationships
`• Delinquent or run away
`• Reports of sexual assault by caretaker
`
`None of the physical or behavioral indicators of sexual abuse as listed in the table above were reported
`to officials or employees at LCSD/LES by Plaintiff AB 511 Doe or his parents as stated in his deposition,
`nor were any of these indicators reported to be observed by any of the teachers as reported by Ruth
`Bane, Anthony Figurilli, Nancy Townsend or Kathleen Hurtgam or Principal Russell Martino in their
`depositions.
`
`Further, in the 1980s it was not uncommon for teachers in rural communities to be involved with their
`community including participation in activities with students and their families outside of the school
`setting. Lyndonville, New York is a “is a small rural village located in Orleans County midway, between
`Buffalo and Rochester. Income is derived primarily from agriculture, particularly orchards and dairy
`farms.” (www.lyndonvillecsd.org/page/district). In a 1982 report to the National Institute of Education
`entitled “the Preparation and Certification of Teachers for Rural and Small Schools”, Gardener and
`Edington state that “In the rural or small school community, the teacher can and should become more
`involved with community activities. The teacher knows and is known by everyone in the community.
`This closeness to the people often results in the teachers becoming the leaders within the community.
`They must, therefore, be able to use the resources available within their community' as well as to work
`with the community.” Other articles on rural education in the period emphasize the relationships,
`connectedness and emotional closeness that rural teachers and administrators work to create with rural
`students and their families. As such, in a rural community such as Lyndonville in the 1980s, it would not
`have been considered unusual for a student to spend time outside of school with an educator with the
`parents’ permission. Educators in rural communities often had multiple roles and relationships with
`their students and their families outside of the classroom that did not involve the school. For example,
`teachers Kathleen Hurtgam, Nancy Townsend and their children were part of the 4-H club with Terry
`Houseman and his wife. Russell Martino stated in his deposition that it was not uncommon for students
`to be sleeping over at teachers’ houses as many of the teachers lived in the community and had children
`who were also students at LCSD/LES and so their friends were often in the teachers’ homes. As
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`described by Plaintiff AB 501 Doe in his deposition, his parents gave permission for him to spend the
`night at Terry Houseman’s home prior to an early morning leadership activity.
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`III.
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`
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`It is my opinion that sexual abuse prevention training was not standard practice in school
`systems in the Unites States in the 1980s.
`
`My opinion is based upon Shakeshaft and Cohen’s 1994 report to the U.S. Department of Education
`entitled “In Loco Parentis: Sexual Abuse of Students in Schools. What Administrators Should Know”. In
`their report, Shakeshaft and Cohen (1994) conclude that “we found no districts where touching and
`contact had been adequately and comprehensively discussed and explored, examining helpful and
`harmful implications” (p38). Additionally, child abuse prevention trainings for educators almost
`exclusively focused on child sexual abuse perpetrated by others (i.e. non-teachers) and research and
`large scale efforts to understand educator sexual abuse were lacking. In her seminal report to the
`Department of Education in 2004, Charol Shakeshaft stated “With rare exceptions, sexual abuse
`prevention training for educators and school staff—whether preprofessional or while on the job— does
`not include educator sexual misconduct”. This still largely remains the case even today as in a 2017
`report to the National Institute of Justice, Grant and colleagues concluded that “Despite the number of
`agencies charged with protecting children from sexual abuse and collecting data on sexual abuse, there
`continues to be very limited prevention, research, or data collection on school employee sexual
`misconduct specifically, making it difficult to gather the information needed to shape prevention efforts
`and extrapolate prevalence rates”.
`
`Further, in 1980, Zgliczynski and Rodolfa surveyed 484 nationally accredited teacher education programs
`in the U.S. about the child abuse topics covered in their preservice programs, and found that of the 40%
`that responded, only 55% provided education on child abuse prevention. Of those, only 8% provided
`comprehensive training which included training on reporting laws, referral sources, identifying abuse
`victims, identifying abusing parents, communicating with abused children, and ethical issues in reporting
`abuse. It should be noted that as discussed in opinion I, the focus on child abuse prevention training
`during this time period, when it was conducted, was on sexual abuse perpetrated by parents/guardians,
`and not educators.
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`In addition, according to New York State Education Law Article 23-B, prior to July 1st, 2001 “no statewide
`standard policy existed for the reporting, investigation or identification of child abuse in the educational
`environment”. It was on only January 1st, 1989, that New York State Education Law required certain
`individuals, when initially applying for licensure or a limited permit (this would apply only to new
`teachers entering the profession), to show that they have completed the required training in the
`identification and reporting of child abuse and maltreatment. Even if training is received, as noted
`above, much of the sexual abuse prevention training is not comprehensive even today. For example, in a
`recent (2021) review of the content of state-sponsored curricula of mandated child abuse reporting
`training found that only one quarter (25%) of the curricula included all four elements of sexual abuse
`reporting including a definition, examples, and child and parent indicators of sexual abuse.
`
`Moreover, guidelines on the development of policies and procedures to prevent child sexual abuse
`within child serving institutions were only comprehensively addressed in a 2007 report entitled
`“Preventing Child Sexual Abuse Within Youth-serving Organizations: Getting Started on Policies and
`Procedures” disseminated by the Centers for Disease Control (Saul & Audage, 2007). Guidelines
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`pertaining to clear lines of vision, open door policies, and directives on out of program contact with
`youth by employees of child serving institutions including schools were first comprehensively delineated
`in this report following a meeting of experts sponsored by CDC in August 2004. Prior to that there were
`no comprehensive national-level guidelines for the development of policies and procedures to prevent
`child sexual abuse within youth serving organizations such as having open door policies.
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`IV.
`
`When allegations of abuse arose in LCSD/LES they were handled swiftly by the administrators
`in line with standard practice of the time.
`
`My opinion is based upon the deposition of Russell Martino, LCSD/LES principal and Shakeshaft and
`Cohen’s 1994 report to the U.S. Department of Education entitled “In Loco Parentis: Sexual Abuse of
`Students in Schools. What Administrators Should Know” in which they found that in the 1990s few
`districts had outlines of reporting procedures and policies when the perpetrator of the abuse was a staff
`member/employee. They found that there was often confusion about the legal responsibilities and
`reporting procedures. Shakeshaft and Cohen found a common pattern in terms of the investigations,
`superintendents would first question the students, with or without the parents’ knowledge. If they felt
`the charges were serious, they would consult their attorney, board president and union president to
`inform them of what was happening and then they would speak to the accused teacher. The authors
`concluded that most investigations were poorly carried out and superintendents rarely contacted the
`police, local district attorney or reported the allegations to child abuse hotlines. In most cases when the
`accused teacher stated that the accusations were not true, or the child misconstrued the alleged
`abusive behavior, this ended the in-house investigation. If allegations were believed to be true, only
`15% of teachers were terminated, 38.7% were allowed to retire, leave the district or resign, while 36.9%
`were reprimanded formally or informally or had a brief suspension before resuming their teaching
`position. In only 1% of the cases did the superintendents try and revoke the teacher’s license. Further
`almost 2 decades later in 2004, Shakeshaft still concluded that “the majority of allegations of educator
`sexual misconduct are not reported to the police by the school districts” (p48).
`
`According to the deposition of Russell Martino he stated that when he received the call at home about
`the alleged abuse perpetrated by Terry Houseman in December of 1990 (this was 3-4 years after the
`abused alleged by AB 511 Doe), he immediately went to the child’s home to speak with the mother and
`her boyfriend. The sheriff was then called within 24 hours and an investigation was started by the
`police. The next day Terry Houseman was called into the superintendent’s office and informed of the
`allegations and removed from the classroom. Russell Martino also reported that Terry Houseman was
`allowed to resign, and his teaching license was revoked. These procedures are in line with mandated
`reporting laws and standard practice for educator sexual misconduct at the time.
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`In addition to the alleged abuse perpetrated by Terry Houseman, Russell Martino also reported that
`when he received allegations of inappropriate touching by the physical education teacher Fred
`Montag(ue) he called the authorities in line with mandated reporter laws. Further according to the
`deposition of Ruth Bane, another teacher, Mr. Hauser, had allegations of inappropriate behaviors levied
`against him and he was terminated immediately. While no further details were available these actions
`are in line with mandated reporter guidelines and meet or exceed standard practice at the time.
`
`Conclusions:
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`1. Sexual abuse perpetrated by educators was not well known or researched in the 1980s.
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`6
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`2. Officials and employees of LCSD/LES could not have known that Terry Houseman was allegedly
`abusing Plaintiff AB 511 Doe based upon his publicly observable behavior in the school or in the
`community and because Plaintiff AB 511 Doe did not report the alleged abuse to anyone.
`3. Sexual abuse prevention training was not standard practice in school systems in the United States
`in the 1980s.
`4. When allegations of abuse by educators arose in LCSD/LES they were handled promptly in line
`with standard practice at the time.
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`Attachments:
`
`Attached and made part of this report are my curriculum vitae (Attachment 1), my fee schedule
`(Attachment 2), and a list of articles referenced in my opinions (Attachment 3).
`
`Elizabeth L. Jeglic Ph.D.
`
`Date: 06/26/2023
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`7
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`Expert Witness & Consultation Fee Schedule for Dr. Elizabeth L. Jeglic 2023
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`Record Review and Research: Review of any pertinent records related to trial, along with research in
`support of the retaining party will be billed at $400 per hour billed in quarter hour increments.
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`Report Writing: Any written reports will be billed at $400/hour of report writing and preparation billed
`at quarter hour increments.
`
`Trial Preparation: All trial preparation (email, videoconferencing and telephone calls) will be billed at
`$400 per hour including waiting time (if applicable), billed in quarter hour increments.
`
`Expert Consultation: Consultation by phone or videoconference will be billed at $400/hour of
`consultation billed at quarter hour increments with a minimum of $400 per consultation.
`
`Deposition/Testimony: All depositions and testimony at trial or at hearings will be billed at $400 per
`hour with a minimum of $3500 per day. This will include time giving or waiting to give deposition or
`testimony, as well as time for meals, breaks and any travel time that takes place on the day of
`deposition/testimony.
`
`In-Person Work: Any in-person work not covered in the above categories will be billed at $400/hour
`with a minimum of $3500 per day plus any travel expenses.
`
`Cancellation: Any cancellation of services less than 96 hours from the time of service/flight will result in
`payment for one day’s services ($3500) plus any travel expenses.
`
`Travel time: Travel time on days other than deposition/testimony days will be billed at $2500 per day
`(regardless of actual hours). Client is responsible for all actual travel expenses including travel, lodging,
`parking and meals.
`
`Retainer Fee: A minimum, non-refundable advance retainer fee of $2500 is required. Initial work will be
`charged against the retainer.
`
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`References
`
`Baker, A. J., LeBlanc, S., Adebayo, T., & Mathews, B. (2021). Training for mandated reporters of child
`abuse and neglect: Content analysis of state-sponsored curricula. Child Abuse & Neglect, 113, 104932.
`
`Boston Globe (2002) https://www.bostonglobe.com/news/special-reports/2002/01/06/church-allowed-
`abuse-priest-for-years/cSHfGkTIrAT25qKGvBuDNM/story.html
`
`Broadhurst, D. D. (1979). The educator's role in the prevention and treatment of child abuse and neglect.
`
`Craven, S., Brown, S., & Gilchrist, E. (2006). Sexual grooming of children: Review of literature and
`theoretical considerations. Journal of sexual aggression, 12(3), 287-299.
`
`Gardener, C. E., & Edington, E. D. (1982). The Preparation and Certification of Teachers for Rural and
`Small Schools.
`
`Grant, B., Wilkerson, S. B., Pelton, D., Cosby, A., & Henschel, M. (2017). A case study of K–12 school
`employee sexual misconduct: Lessons learned from title IX policy implementation.
`
`H.R.1 - 107th Congress (2001-2002): No Child Left Behind Act of 2001. (2002, January 8).
`https://www.congress.gov/bill/107th-congress/house-bill/1
`
`Jeglic, E. L., Winters, G. M., & Johnson, B. N. (2023). Identification of red flag child sexual grooming
`behaviors. Child Abuse & Neglect, 136, 105998.
`
`Lesher, M. R., & Wade, S. (1972). A Study of Teacher Employment Practices in Iowa, Kansas, Missouri
`and Nebraska.
`
`Lanning, K. (2018). The evolution of grooming: Concept and term. Journal of Interpersonal
`Violence, 33(1), 5-16.
`
`McAlinden, A. M. (2006). ‘Setting’Em Up’: Personal, familial and institutional grooming in the sexual
`abuse of children. Social & Legal Studies, 15(3), 339-362.
`
`New York State Child Protective Services Act of 1973
`
`New York State Education Law Article 23-B
`
`New York State Safe Schools Against Violence in Education (“SAVE”) Act (2000). McKinney’s 2000
`Session Laws of N.Y. Ch. 180
`
`Saul J., Audage N.C. (2007). Preventing Child Sexual Abuse Within Youth-serving Organizations: Getting
`Started on Policies and Procedures. Atlanta (GA): Centers for Disease Control and Prevention, National
`Center for Injury Prevention and Control
`https://www.cdc.gov/violenceprevention/pdf/PreventingChildSexualAbuse-a.pdf
`
`Shakeshaft, C. (2004). Educator sexual abuse: A synthesis of existing literature. Washington, DC: U.S.
`Department of Education, Office of the Under Secretary. Retrieved from
`http://www.ed.gov/rschstat/research/pubs/misconductreview
`
`Shakeshaft, C., & Cohan, A. (1994). In Loco Parentis: Sexual Abuse of Students in Schools. What
`Administrators Should Know.
`
`Spenard, K., & Cash, D. (2022): Retrospective perceptions of grooming in same-sex versus opposite-sex
`child sexual abuse, Journal of Child Sexual Abuse, DOI: 10.1080/10538712.2022.2123755
`
`Time Magazine (2019) https://time.com/longform/boy-scouts-sex-abuse/
`
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`Wolf, M. R., Linn, B. K., & Pruitt, D. K. (2018). Grooming child victims into sexual abuse: A psychometric
`analysis of survivors’ experiences. Journal of sexual aggression, 24(2), 215-224.
`
`Williams, A.. (2015). Child Sexual Victimisation: Ethnographic Stories of Stranger and Acquaintance
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