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Summons and Complaint

Summons and Complaint

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Published by Newsday

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Published by: Newsday on Jun 29, 2011
Copyright:Attribution Non-commercial

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11/15/2012

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY
OF SUFFOLKTHE PEOPLE OF THE STATE OF NEW YORK, byERIC T. SCHNEIDERMAN, Attorney General
of
theState
of
New
York,Plaintiff,-against COALITION AGAINST BREAST CANCER, INC.,
ANDREW
SMITH, DEBRA KOPPELMAN,PATRICIA SCOTT, CAMPAIGN CENTER, INC.,AND
GARRETT
MORGAN,Defendants.Index No.
SUMMONSPlaintiff
designates Suffolk
County
as
the
place
of
trial
TO THE
ABOVE-NAlVIED DEFENDANTS:YOU
ARE HEREBYSUMMONED
to answer
in
this action and serve a copy
of
your answer (or
if
the complaint
is
not served with the summons, to service a notice
of
appearance) on the
Plaintiffs
attorney within twenty (20) days after the service
of
thissummons, exclusive
of
the day
of
service.
If
this summons is not personally served upon you, or
if
this summons is servedupon you outside
of
the State
of
New York, then your answer
or
notice
of
appearance mustbe served within thirty (30) days.
If
you fail to appear or answer, judgment will be taken against you by default forthe relief demanded in the complaint.Dated: New York, New York ERIC T.
SCHNEIDERMAN
June
27,2011
Attorney General
of
the State
of
New
York.
- ~ " ' ,
 
.
'r0
By:
~ ~ ~ 7
 
Caroline PressAssistant Attorney General, Charities Bureau120 Broadway, 3
rd
FloorNew York,
New
York 10271
(212) 416-8401
 
TO:
COALITION AGAINST BREAST CANCER,
INC.
ANDREW SMITHDEBRA KOPPELMANPATRICIA SCOTTCAMPAIGN CENTER,
INC.
GARRETT MORGAN
2
 
SUPREME COURT OF THE STATE OF
NEW
YORK
COUNTY
OF SUFFOLK
THE
PEOPLE OF THE STATE OF
NEW
YORK, byERIC SCHNEIDERMAN Attorney General
of
theState
of
New York,Plaintiff,-against COALITION AGAINST BREAST CANCER, INC.,
ANDREW
SMITH, DEBRA KOPPELMAN,PATRICIA SCOTT, CAMPAIGN CENTER, INC.,
AND
GARRETT MORGAN,Defendants.Index No.
COMPLAINT
Eric
T.
Schneiderman, AttoD1ey General
of
the State
of
New York,
on
behalf
of
thePeople
of
the State
of
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
New
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
1.
CABC
is
a sham charity that has diverted nearly all
of
the millions
of
dollarsraised in the name
of
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,
CASC

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