`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
`
`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF RENSSELAER
`--------------------------------------------------------------------------X
`T.T.,
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`Plaintiff,
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`-against-
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`HOOSIC VALLEY CENTRAL SCHOOL DISTRICT,
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`PLAINTIFF’S FIRST SET OF
`INTERROGATORIES TO
`DEFENDANT.
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`
`
`Index No.: EF2021-269598
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`
`
`
`
`Defendants.
`--------------------------------------------------------------------------X
`PLEASE TAKE NOTICE that Plaintiff demands separate and complete answers under oath
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`
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`to each of these interrogatories within twenty days of service as prescribed by the New York Civil
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`Practice Law and Rules. Pursuant to subdivision (h) of CPLR 3101 you are required to amend or
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`supplement an answer previously given to an interrogatory promptly upon you thereafter obtaining
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`information that an answer was incorrect or incomplete when made, or that the answer, though
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`correct and complete when made, no longer is correct and complete, and the circumstances are
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`such that a failure to amend or supplement the response would be materially misleading.
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`GENERAL INSTRUCTIONS AND DEFINITIONS
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`Except as otherwise expressly indicated:
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`As used herein, the terms “you,” “your,” “Defendant,” and “HOOSIC VALLEY
`1.
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`CSD” refer to Defendant HOOSIC VALLEY CENTRAL SCHOOL DISTRICT including, any of
`its subsidiaries and any of its employees, agents, contractors or representatives. This includes, but
`is not limited to, secretaries, schools, principals, teachers, coaches, employees, boards, directors,
`subsidiaries,
`counselors,
`associates,
`investigators,
`independent
`contractors,
`agents,
`representatives, accountants, volunteers, attorneys, and affiliated business entities, schools, any
`affiliated or parent entities of any form.
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`As used herein, the term “Complaint” means the Child Victims Act Litigation
`2.
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`Complaint served in the matter with the above-referenced Index Number.
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`As used herein, the term “Plaintiff” means the plaintiff identified in the Complaint.
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`3.
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`1 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`The actor touching a minor’s intimate parts; the touching by the minor of
`a.
`the actor’s, the minor’s, or another’s intimate parts effected by the use of a
`position of authority, or by the inducement of the actor;
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`The actor otherwise inappropriately touching a minor; including, but not
`b.
`limited to, massaging parts of the minor’s body or kissing the minor on the lips;
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`Sexual intercourse, cunnilingus, fellatio, anal intercourse, or an intrusion,
`c.
`however slight, into the genital or anal openings:
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`As used herein, the term “employee” shall refer to any employee of Defendant and
`4.
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`includes, but is not limited to, employees, volunteers, independent contractors, agents, janitors,
`custodians, teachers, coaches, staff, directors, officers, board members, and the like.
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`The term “or” is not exclusive and shall be construed both conjunctively and
`5.
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`disjunctively in each request.
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`The term “and” is not exclusive and shall be construed both conjunctively and
`6.
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`disjunctively in each request.
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`As used herein the term “position of authority” as that term is used above includes,
`7.
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`but is not limited to: any person who is charged with any duty or responsibility for the education,
`guidance, counseling, welfare, health, or supervision of a child under the age of eighteen, either
`independently or through another, no matter how brief, at the time of the act.
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`As used herein, the term “sexual misconduct” means any of the misconduct referred
`8.
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`to in CPLR 208 (b) or CPLR 214-g, including, but not limited to:
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`Of the complainant’s body by any part of the actor’s body or any
`i.
`object used by the actor for this purpose;
`
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`Of the complainant’s body by any part of the body of the
`ii.
`complainant, by any part of the body of another person, or by any object
`used by the complainant or another person for this purpose, when effected
`by the use of a position of authority or by the inducement of the actor;
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`Of the body of the actor of another person by any part of the body
`iii.
`of the complainant of by any object used by the complainant for this
`purpose, when effected by use of a position of by the inducement of the
`actor.
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`The actor talking, writing or communicating in any way with a minor
`d.
`regarding anything of a sexual nature; and
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`2
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`2 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`The actor having a minor in the actor’s private living quarters, including
`e.
`the actor’s bedroom.
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`The actor engaging in unconsented to sexual activity with an adult; or the
`f.
`actor otherwise sexually touching the adult without consent.
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`“Person” means any natural person or any business, legal or governmental entity or
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`“Concerning” means relating
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`to, referring
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`to, describing, evidencing or
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`As used herein the term “boundary violation” shall mean communications,
`9.
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`observations, rumors, suspicions, patterns of behavior, course of conduct, or activity by an adult
`with a minor child that might be an indicator of inappropriate behavior by that adult, including,
`but not limited to, buying gifts for a child, giving money to a child, touching a child in a way that
`makes the child uncomfortable, giving a child extra or special attention, spending time with a child
`alone without other adult supervision, kissing a child on the lips, sharing a bed with a child,
`viewing pornography with a child, being alone with a child in a meeting, being alone with a child
`in a classroom, close physical contact with a child such as lap sitting, knee touching and hugging,
`tickling a child, massaging a child or having a child massage the adult, commenting on a child’s
`body or appearance, physically disciplining a child, wrestling with a child, giving a child alcohol
`or drugs, violating the boundaries of a child, allowing a child to spend the night in the rectory, or
`taking overnight trips with a child that are unrelated to an official event or function.
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`10.
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`association.
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`11.
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`constituting.
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`The term “communication” means the transmittal of information (in the form of
`12.
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`facts, opinions, ideas, inquiries, or otherwise).
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`The term “document” means, regardless of origin or location, any book, pamphlet,
`13.
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`periodical, letter, memorandum, writing, telegram, email, text message, report, record, study, note,
`working paper, graph, drawing, chart, photograph, image, film, video recording, audio recording,
`index, tape, disk, data sheet or data processing card, electronically stored information, or any other
`written, recorded, transcribed, punched, taped, filmed or graphic matter, however produced or
`reproduced, to which you have or have had access. “Document” shall include originals (or copies
`if originals are not available) and nonidentical copies (whether different from the original because
`of handwritten notes or underlining or otherwise) and any translations of any document.
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`“Electronically Stored Information” or “ESI” includes any electronically stored
`14.
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`information stored in any medium from which such information can be obtained, either directly or
`after translation by the responding party into a reasonably usable form.
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`Any word written in the singular shall also be construed as plural and any word
`15.
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`written in the plural shall also be construed in the singular.
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`3
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`3 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`Reference to any entity includes each of its officials, officers, directors, employees,
`16.
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`agents, attorneys, or other persons acting or purporting to act on behalf of the foregoing, whether
`currently or formerly employed or retained in these capacities.
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`17. When referring to a natural person, stating the “identity” means to give, to the
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`extent known, the person’s (a) full name, (b) present or last known address, and (c) the present or
`last known place of employment. Once a person has been identified in accordance with this
`paragraph, only the name of that person need be listed in response to subsequent discovery
`requesting the identification of that person.
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`18. When referring to an entity, stating the “identity” means to give, to the extent
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`known, (a) the entity’s full name, including (when not apparent from the name) the nature of the
`entity, e.g. corporation, limited liability corporation, partnership, professional corporation,
`religious organization, religious institute, religious society, religious house, religious order, juridic
`person, or moral person, (b) present or last known address of its headquarters or principal place of
`business, and (c) the state in which the entity is incorporated or otherwise created. Once an entity
`has been identified in accordance with this paragraph, only the name of that entity need be listed
`in response to subsequent discovery requesting the identification of that entity.
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`19. When referring to documents, to “identify” means to give, to the extent known, (a)
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`the type of document; (b) the general subject matter; (c) the date of the document; (d) the author
`or authors, according to the document; (e) the persons to whom, according to the document (or a
`copy) was to have been sent; and (f) the current location of the document.
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`As used herein, the term “describe” means to state fully and with particularity a
`20.
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`description responsive to the interrogatory, including but not limited to, stating each date, fact,
`event, occurrence, allegation, claim or defense; stating the identity of each individual who can
`testify, or who could have testified, as to each date, fact, event, occurrence, allegation, claim or
`defense; and identifying the documents concerning each date, fact, event, occurrence, allegation,
`claim or defense.
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`If any document, or any portion of any document, is withheld under claim of
`21.
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`attorney-client privilege or upon any other ground, the respondent withholding the document shall
`furnish a list, signed by the person supervising the response to this request, identifying each
`document withheld and stating with respect to each:
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`the legal ground for withholding such document;
`a.
`the type of document;
`b.
`the general subject matter of the document;
`c.
`the date of the document; and
`d.
`the number of pages of the document, the identities of the document’s
`e.
`author, addressee, and each person to whom copies were sent or were to be sent,
`including the identity of each person to whom the document, its contents, or any
`portion thereof is known or has been disclosed, and any other information as is
`sufficient to identify the document for a subpoena duces tecum.
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`4
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`4 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`The term “relevant time period” refers to, unless otherwise specified, the period to
`22.
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`the present from the first date JACK SCERBO was considered for employment with Defendant.
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`INTERROGATORIES
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`1.
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`Identify all persons answering these interrogatories, the interrogatories they answered and
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`their association and/or position with Defendant.
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`2.
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`Describe the relationship between JACK SCERBO and the Defendant, including, but not
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`limited to, the following:
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`a. The circumstances surrounding the initial association between or among them,
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`including the relationship between Defendant and JACK SCERBO;
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`b. Each assignment of JACK SCERBO at or with the Defendant and set forth the years
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`he served in each position, his title and duties, and the reasons for any
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`reassignments, transfers, retirement, leaves of absence, periods of restriction,
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`periods of psychological, physical, or other medical treatment lasting more than
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`one week;
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`c. The method by which JACK SCERBO was compensated by Defendant for each
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`position to which he was assigned by Defendant, including the amount, nature,
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`source and frequency of his compensation;
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`d. The specific duties and responsibilities of JACK SCERBO for each position to
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`which he was assigned by Defendant;
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`e. If JACK SCERBO had specific duties and responsibilities outside of his assigned
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`positions, but during his association with Defendant, then please also state those
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`specific duties and responsibilities;
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`f. State the identities of JACK SCERBO’s supervisor(s) during his association with
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`Defendant, including his supervisors at each assigned position with Defendant.
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`5
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`5 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`g. Did Defendant ever have any occasion to discipline JACK SCERBO? If so, for
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`each disciplinary event state the date(s); the person(s) reporting the incident; the
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`person(s) investigating the incident; and the person(s) deciding the discipline.
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`3.
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`State the identity of all person(s) Defendant contends has knowledge or claims to have
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`knowledge of any facts relating to the incidents which are the subject matter of this
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`Complaint, and state for each such person their address, phone number and the nature of
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`such knowledge.
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`4.
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`State the identity of each person or entity Defendant (its agents, investigators or attorneys)
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`has contacted or spoken to, at any time, concerning the facts relating to the incidents which
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`are the subject matter of this Complaint or your defenses to this Complaint. For each
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`person/entity state the following:
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`a. Whether documents concerning the contact exists, and if so please identify such
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`documents;
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`b. If a statement was taken, identify the date on which it was taken and state the
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`identity of the person who took the statement.
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`5.
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`Identify all communications Defendant (its agents, investigators or attorneys) has had with
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`Plaintiff regarding the subject matter of this Complaint.
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`6.
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`Is Defendant aware of any legal action or insurance claims brought by Plaintiff prior to the
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`institution of this lawsuit? If so, please furnish all information you possess in this regard,
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`including dates, nature of the claims and final disposition of any claims made.
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`7.
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`Has Defendant, its agents, or attorneys at any time received any medical report, oral or
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`written, x-ray report, hospital records or writings of any kind from any medical
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`practitioners, psychiatrists, psychologists, hospitals, counselors or social workers, whether
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`6
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`6 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`licensed or non-licensed, regarding the medical, physical, mental or emotional condition
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`of Plaintiff before, during or after the occurrences which are the subject matter of this
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`Complaint? If so, please provide the name and address of the person(s), clinics, hospitals
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`or other institutions from which the information was originally received by Defendant or
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`its representatives.
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`8.
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`State whether Defendant has ever had or currently has any claims, complaints and/or
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`allegations against it regarding sexual abuse of minors, other than the allegations which are
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`the subject matter of this Complaint. If so, state the identity of the persons making the
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`claims, complaints and/or allegations; state the date of each such claim, complaint and/or
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`allegation; describe the nature of the claims, complaints and/or allegations; state the
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`identity of the alleged perpetrators for each such claim, complaint and/or allegation; and
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`identify the documents relating to the claims, complaints and/or allegations. In addition,
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`please identify all staff, including but not limited to, teachers, coaches, etc., who have
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`worked or continue to work for Defendant who has been accused of boundary violations,
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`attempted sexual misconduct, sexual misconduct or other inappropriate behavior with
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`minors during the relevant time period.
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`9.
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`Describe in detail the process by which JACK SCERBO was initially hired for a position
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`by Defendant, including the processes or procedures used by Defendant to evaluate JACK
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`SCERBO’s fitness for employment and efforts made by Defendant to ensure that fitness.
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`Include the identities of any persons contacted by Defendant as reference checks for JACK
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`SCERBO.
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`10.
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`Does Defendant have knowledge of any claims, complaints and/or allegations made against
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`JACK SCERBO for boundary violations, attempted sexual misconduct, sexual misconduct
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`7
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`7 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`or other inappropriate conduct with any individual, including the Plaintiff, before, during
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`or after the incidents which are the subject matter of this action? If so, please state
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`separately for each:
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`a. The identity of all persons who informed Defendant of these claims, complaints
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`and/or allegations;
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`b. The identity of each individual involved in the claimed, purported, reported, and/or
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`alleged boundary violations, attempted sexual misconduct, sexual misconduct or
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`other inappropriate conduct;
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`c. The dates and nature of the boundary violations, attempted sexual misconduct,
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`sexual misconduct or other inappropriate conduct that was purported to have
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`occurred;
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`d. If criminal charges or civil damage claims resulted from such claimed, purported,
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`reported, and/or alleged boundary violations, attempted sexual misconduct, sexual
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`misconduct or other inappropriate conduct, state the identity of the parties to that
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`action; the venue of court in which that action was filed, brought or commenced;
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`the court index, docket or file number; and the ultimate disposition of the charge,
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`action or litigation;
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`e. The date Defendant became aware of such allegations, stating the identity of the
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`particular employee(s) and/or agent(s) who became aware of these allegations;
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`f. Identify the documents, or other tangible evidence concerning in any manner
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`Defendant’s knowledge of claimed, purported, reported, and/or alleged boundary
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`violations, attempted sexual misconduct, sexual misconduct or other inappropriate
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`conduct committed by JACK SCERBO;
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`8
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`8 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`g. If JACK SCERBO admitted to the allegations of boundary violations, attempted
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`sexual misconduct, sexual misconduct or other inappropriate conduct, provide the
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`date of and substance of such admissions and identify the Defendant’s agents who
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`became aware of any of those admissions;
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`h. Describe any disciplinary or preventative actions Defendant took in response to
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`knowledge of such boundary violations, attempted sexual misconduct, sexual
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`misconduct or other inappropriate conduct.
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`11.
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`Does Defendant have knowledge of any claims, complaints and/or allegations made against
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`any of its employees, agents or representatives of Defendant, for boundary violations,
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`attempted sexual misconduct, sexual misconduct or other inappropriate conduct with any
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`individual, including the Plaintiff, before, during or after the incidents which are the subject
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`matter of this Complaint? If so, please state separately for each:
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`a. The identity of all persons who informed Defendant of these claims, complaints
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`and/or allegations;
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`b. The identity of each individual involved in the claimed, purported, reported, and/or
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`alleged boundary violations, attempted sexual misconduct, sexual misconduct or
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`other inappropriate conduct;
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`c. The dates and nature of the act or acts of the boundary violations, attempted sexual
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`misconduct, sexual misconduct or other inappropriate conduct that was purported
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`to have occurred;
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`d. Whether Defendant reported such boundary violations, attempted sexual
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`misconduct, sexual misconduct or other inappropriate conduct to law enforcement
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`authorities. If reported to authorities, state the identity of the individual who made
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`9
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`9 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`the report, the date on which it was made, and the identity of the person to whom
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`the report was made;
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`e. If criminal charges or civil damage claims resulted from such claimed, purported,
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`reported, and/or alleged boundary violations, attempted sexual misconduct, sexual
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`misconduct or other inappropriate conduct, identify the parties to that action, the
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`venue of court in which that action was filed, brought or commenced; the court
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`index, docket or file number and the ultimate disposition of the charge, action or
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`litigation;
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`f. The date Defendant became aware of such allegations, stating the identity of the
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`particular agent or agents who became aware of these allegations;
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`g. Identify the documents, or other tangible evidence relating in any manner to
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`Defendant’s knowledge of claimed, purported, reported, and/or alleged boundary
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`violations, attempted sexual misconduct, sexual misconduct or other inappropriate
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`conduct committed by any of its agents;
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`h. If a party claimed, purported, reported, and/or alleged to have committed boundary
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`violations, attempted sexual misconduct, sexual misconduct or other inappropriate
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`conduct admitted the allegations of such misconduct, provide the date of and
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`substance of the admission and state the identity of the Defendant’s agents who
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`became aware of the admission;
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`i. Describe any disciplinary or preventative actions the Defendant took in response to
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`knowledge of this sexual or physical misconduct;
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`j. State whether any individual claimed, purported, reported, and/or alleged to have
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`committed boundary violations, attempted sexual misconduct, sexual misconduct
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`10
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`10 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`or other inappropriate conduct received an assignment following such accusations.
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`If any such accused individual did receive an assignment following the receipt by
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`Defendants of a claim, accusation, report or allegation that that individual
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`committed boundary violations, attempted sexual misconduct, sexual misconduct
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`or other inappropriate conduct state the location of that assignment and the date on
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`which it began;
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`k. State whether any persons at such accused individual’s subsequent assignments
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`were informed of any claim, accusation, report or allegation that that individual had
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`previously committed boundary violations, attempted sexual misconduct, sexual
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`misconduct or other inappropriate conduct. If yes, please list state the identities of
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`the individuals who were informed.
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`12.
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`Does Defendant have knowledge of any psychiatric, psychological or other therapy or
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`counseling JACK SCERBO has undergone either before, during or after the incidents
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`which are the subject matter of this action? If so, state the following:
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`a. The identity of the person(s) who counseled or provided therapy for JACK
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`SCERBO and the dates of this therapy or counseling;
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`b. Whether Defendant or its agents, servants or employees directed or suggested that
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`JACK SCERBO undergo this therapy or counseling. If so, please state the
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`identities of the individuals who directed or suggested that JACK SCERBO
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`undergo such therapy or counseling, and the date(s) of such directions or
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`suggestions;
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`c. Identify the documents in Defendant’s possession relating in any way to such
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`therapy or counseling.
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`11
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`11 of 15
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`13.
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`Describe Defendant’s written and unwritten policies and/or procedures concerning the
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`duties and obligations of teachers, coaches, educational staff, and others serving within the
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`structure of Defendant, that arose when they received any reports, allegations, or suspicions
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`of boundary violations, attempted sexual misconduct, sexual misconduct or other
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`inappropriate conduct which were in effect during the during.
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`14.
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`Describe in detail the document filing system and document retention policy of the
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`Defendant during the time period of the events described in the Complaint. Describe in
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`detail the document filing system and document retention policy of each, school, or
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`assignment where JACK SCERBO was assigned while employed by Defendant as an
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`employee, independent contractor, and/or agent.
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`15.
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`Describe in detail and identify all documents relating to JACK SCERBO while he was
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`employed or being considered for employment with the Defendant. If these files are no
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`longer in your possession, for each document no longer in your possession state where you
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`sent the document, to whom the document was addressed/sent, the subject of the document,
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`the current location of the document, the date of the document, and any other information
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`you have concerning the document.
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`16.
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`Identify the person who has the most knowledge within Defendant concerning JACK
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`SCERBO and/or his duties and/or history and/or any claims, allegations or suspicions of
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`inappropriate conduct whatsoever.
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`17.
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`Identify the person who has the most knowledge within the Defendant concerning what to
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`do when claims, allegations or suspicions of boundary violations, attempted sexual
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`misconduct, sexual misconduct or other inappropriate conduct has been reported, claimed
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`or alleged to Defendant and/or Defendant’s sexual abuse prevention policies, education,
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`training and/or prevention during the relevant time period.
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`18.
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`State the identity of all witnesses and expert witnesses that Defendant, its agents or
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`attorneys will call at the hearing/trial of this matter. State the identity of each person
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`whom you expect to call as an expert witness at the time of trial, including in reasonable
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`detail the subject matter on which each expert is expected to testify; the substance of the
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`facts and opinions on which each expert is expected to testify; and the qualifications of
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`each expert witness and a summary of the grounds for each expert’s opinion.
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`19.
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`Please state the identity of any witnesses which support any of your affirmative or other
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`defenses, please identify any documents which support any of your affirmative or other
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`defenses, and please describe any facts or circumstances which support any of your
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`affirmative or other defenses.
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`20.
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`If Plaintiff was in the presence of JACK SCERBO after normal school hours, please state
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`the number of occasions same occurred including but not limited to:
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`a.
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`b.
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`c.
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`d.
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`The dates of such contact;
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`The places of such contact;
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`The reasons for such contact;
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`The number of occasions where sexual misconduct occurred.
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`21.
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`Has JACK SCERBO ever been prosecuted criminally for sexual misconduct, or accused
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`of sexual misconduct by any person? If so, and for each occasion, please state when;
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`where the alleged misconduct occurred; the name of the law enforcement agency; and the
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`name of the alleged victim or accuser.
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
`NYSCEF DOC. NO. 15
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 01/11/2022
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`22.
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`Did anyone on behalf of the Defendant ever make contact with, either verbally or in
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`writing, JACK SCERBO’s subsequent employer(s) regarding his any claims, allegations
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`or suspicions of inappropriate conduct whatsoever. If so, please identify the person who
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`made such communications, provide his/her last known address and telephone number, and
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`identify any written documents describing same.
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`23.
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`Did any student at HOOSIC VALLEY CSD, or any other of Defendant’s schools, report
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`to HOOSIC VALLEY CSD officials that JACK SCERBO, or any other employee, teacher,
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`agent, independent contractor, or volunteer, sexually abused/assaulted them or was
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`otherwise acting in a sexually inappropriate manner? If so, please state HOOSIC VALLEY
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`CSD’s position within Defendant at the time, when this occurred, who the alleged
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`perpetrator was, the acts that were alleged, who the victim was, any investigation that
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`ensued, and any consequences/discipline that was given to the alleged perpetrator.
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`24.
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`Did anyone on behalf of the Defendant have knowledge at any time that JACK SCERBO
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`was keeping students after class to abuse them or that he would follow students to the
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`bathroom to expose himself? If so, please state the identity of the person who had
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`knowledge, when he/she obtained this knowledge, how he/she obtained this knowledge,
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`what investigation was completed, and any discipline levied against JACK SCERBO.
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`Dated: New York, New York
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` January 11, 2021
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`HERMAN LAW
`
`_________________________
`Alexandra Slater, Esq.
`Attorney for Plaintiff
`434 West 33rd Street, 13th Floor
`New York, NY 10005
`212-390-0110
`aslater@hermanlaw.com
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`FILED: RENSSELAER COUNTY CLERK 01/11/2022 05:45 PM
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`NYSCEF DOC. NO. 15
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`
`INDEX NO. EF2021-269598
`INDEX NO. EF2021-269598
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`YSCEF: 01/11/2022
`RECEIVED NYSCEF: 01/11/2022
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`
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`AFFIDAVIT OF SERVICE
`
`STATE OF NEW YORK
`)
`COUNTY OF NEW YORK -
`
`Kristina Meza-Schmied, being duly sworn, deposes and says: That she is not a party to
`this action, is over 18 years ofage and conducts business in New York County, New York.
`On the 11" day of January, 2022,| served on all parties the within PLAINTIFF’S FIRST
`SET OF INTERROGATORIES TO DEFENDANT. upon the attorneys whose names and
`addresses are set forth below by, via the New York State Unified Court System, Electronic Filing
`(NYSCEFP), a copy of which has been forwarded to counsel via electronic means.
`GIRVIN & FERLAZZO.P.C
`20 Corporate Woods Blvd.
`Albany, NY 12211
`pjff@girvinlaw.com
`
`Pehle
`3
`ie
`
`BEEVY Kristina Meza-SchmiedA OF:
`
`
`
`Sworn to before methis
`11" day of January, 2022.
`na VU.
`¢
`
`/
`
`7
`
`/
`
`LISA M ELLIS
`Notary Public, State of New York
`No. O1E.6033824
`Qualified in Cayuga Cou
`aut
`MyCommissionExpiresNovember39,202?
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`15 of 15
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