SUPREME COURT OF THE STATE OF
PEOPLE OF THE STATE OF
YORK, byERIC SCHNEIDERMAN Attorney General
New York,Plaintiff,-against COALITION AGAINST BREAST CANCER, INC.,
SMITH, DEBRA KOPPELMAN,PATRICIA SCOTT, CAMPAIGN CENTER, INC.,
GARRETT MORGAN,Defendants.Index No.
Schneiderman, AttoD1ey General
New York, alleges the following against Coalition Against Breast Cancer,Inc., a New York not-for-profit corporation ("CABC"); Andrew Smith ("Smith"), Debra.Koppelman ("Koppelman"), and Patricia Scott ("Scott"), CABC's officers and directors;Campaign Center, Inc., a
York business corporation ("Campaign Center"); and GarrettMorgan, Campaign Center's founder and president ("Morgan," and collectively with CABC,Koppelman, Smith, Scott and Campaign Center, the "Defendants").
NATURE OF THE CASE
a sham charity that has diverted nearly all
dollarsraised in the name
breast cancer to its officers, directors and fundraisers. Falsely claimingresearch affiliations with hospitals such as Memorial Sloan-Kettering and using other lies andexaggerations, Defendants deceive donors into believing that their donations will help eradicatebreast cancer through research, mammogran1 screening and other programs. In reality,