UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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MARIE ANNE THOMAS, LEVERETT HOLMES, JOSEFINA CRUZ,
BRIAN SALAZAR, DAVID PAKTER, PAUL SANTUCCI
ECF CASE:
On behalf of all persons similarly situated pedagogues
Or tenured educational personnel unfairly brought up
on 3020-a Disciplinary Charges since the 2002
abolishment of the NYC Board of Education and
subjected to unlawful confinement in Teacher
Reassignment Centers a/k/a Rubber Rooms,
Plaintiffs,
-against-
CLASS ACTION
COMPLAINT FOR
DECLARATORY,
NEW YORK CITY DEPARTMENT OF EDUCATION
INJUNCTIVE AND
f/k/a BOARD OF EDUCATION OF THE CITY
OTHER RELIEF
SCHOOL DISTRICT OF THE CITY OF NEW YORK;
JOEL I. KLEIN, in his official capacity as Chancellor of the
CITY SCHOOL DISTRICT OF THE CITY
OF NEW YORK and individually;
JURY TRIAL IS
LAWRENCE BECKER, in his official capacity as
DEMANDED
Chief Executive Officer DIVISION OF HUMAN
RESOURCES and individually;
PHILIP CROWE, in his official capacity as
HUMAN RESOURCES DIRECTOR, and individually;
JUDITH RIVERA, in her official capacity as DEPUTY
HUMAN RESOURCES DIRECTOR and individually;
Defendants.
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Plaintiffs Marie Ann Thomas, Leverett Holmes, Josefina Cruz, Brian Salazar, David Pakter, Paul
Santucci, on behalf of all similarly situated pedagogues, i.e. tenured educational personnel
unfairly brought up on 3020-a Disciplinary Charges since the 2002 abolishment of the NYC
Board of Education, who were and many still are, subjected to unlawful confinement in Teacher
Reassignment Centers a/k/a Rubber Rooms where Plaintiffs and the Plaintiff class members
were, are and/or continue to be (i) confined based on charges that are improperly brought without
statutorily required school board vote, wi