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Affirmation of Jon Schuyler Brooks in Support of Plaintiffs' Motion for Partial Summary Judgment

Affirmation of Jon Schuyler Brooks in Support of Plaintiffs' Motion for Partial Summary Judgment

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Published by Marc Landis
Index No. 107173-2011, Supreme Court of the State of New York, New York County

Steglich, Cherwin et al v Board of Education of the City School District of the City of New York, et al. (Steglich II)
Index No. 107173-2011, Supreme Court of the State of New York, New York County

Steglich, Cherwin et al v Board of Education of the City School District of the City of New York, et al. (Steglich II)

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Published by: Marc Landis on Aug 11, 2011
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08/11/2011

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1151047.2
 SUPREME COURT OF THE STATE OF NEW YORKAPPELLATE DIVISION: FIRST DEPARTMENT-----------------------------------------------------------------------LISA STEGLICH, individually and as parent and naturalguardian of ALEXANDER HERLIHY, infant, RICCHERWIN, individually and as parent and natural guardianof MARLEY CHERWIN, infant, CAROL BARKER,individually and as parent and natural guardian of OMARIBROWN, infant, GINA DEMETRIUS, individually and asparent and natural guardian of SEBASTIANDEMETRIUS, KIMBERLY JARNOT, individually and asparent and natural guardian of MARGARET THOMAS,infant, NYDIA JORDAN, individually and as parent andnatural guardian of HARRY D. JORDAN, infant,KAVERY KAUL, individually and as parent and naturalguardian of ASHOK KAUL, infant, RUBEN andGERALDINE LOPEZ, individually and as parents andnatural guardians of SHANE LOPEZ, infant, MADELINEOLMEDA, individually and as parent and natural guardianof CRISTINA JULLIA CRUZ, infant, LAZARAQUINONES, individually and as parent and naturalguardian of DORIS ALCANTARA, infant, andMARILYNN SARJEANT, individually and as parent andnatural guardian of ALIYA CLUNIE, infant,Plaintiffs-Appellants,-against-THE BOARD OF EDUCATION OF THE CITY SCHOOLDISTRICT OF THE CITY OF NEW YORK a/k/a THEPANEL FOR EDUCATIONAL POLICY, THEDEPARTMENT OF EDUCATION OF THE CITY OFNEW YORK, and DENNIS M. WALCOTT, as Chancellorof the City School District of the City of New York,Defendants-Respondents,- and -UPPER WEST SUCCESS ACADEMY CHARTERSCHOOL a/k/a SUCCESS ACADEMY CHARTERSCHOOL, MATTHEW MOREY, individually and asparent and natural guardian of infants THOMAS MOREYand CLAIRE MOREY, MARTIN AARES, individuallyand as parent and natural guardian of infant SABINEBALOU-AARES, GABRIEL BAEZ, individually and as::::::::::::::::::::::
NEW YORK COUNTYIndex No. 107173/11AFFIRMATION OFJON SCHUYLER BROOKS
FILED: NEW YORK COUNTY CLERK 08/03/2011
INDEX NO. 107173/2011NYSCEF DOC. NO. 106RECEIVED NYSCEF: 08/03/2011
 
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 parent and natural guardian of infant CHRISTOPHERBAEZ, LISBETH DELOSSANTOS, individually and asparent and natural guardian of infant MIYAH MUZO,ELANA KILKENNY, individually and as parent andnatural guardian of infant LIAM KILKENNY, ELISSAKLEIN, individually and as parent and natural guardian of infant AVA KLEIN, REBECCA KUHAR, individually andas parent and natural guardian of infant ROBERTMAXWELL KUHAR, LATISHA SINGLETARY,individually and as parent and natural guardian of infantRANIYA GARRETT-WELLS, MICHAEL SUCHANEK,individually and as parent and natural guardian of infantsSALLY SUCHANEK and AMELIA SUCHANEK, andDAVID TURNOFF, individually and as parent and naturalguardian of infant HUNTER KIM-TURNOFF,Intervenor-Defendants-Respondents.:::::::::----------------------------------------------------------------------- xJON SCHUYLER BROOKS, an attorney admitted to practice in the state of New York,hereby affirms the following under the penalty of perjury:1.
 
I am a partner at Phillips Nizer LLP, attorney for Plaintiffs-Appellants in thisaction.2.
 
On December 17, 2010, Defendant the Board of Education of the City SchoolDistrict of the City of New York, n/k/a the Panel on Educational Policy (“PEP”) published adocument in English titled “Public Notice” (the “Notice”) concerning “The Proposed Co-location of a New Public Charter School, Success Academy Charter School [(‘SACS”)], withExisting Schools in the Brandeis Educational Campus [(“Brandeis Campus”)] .” Among otherthings, the Notice specified that PEP would consider the proposal to co-locate SACS into the
 
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 Brandeis Campus (the “Co-Location Proposal”) at a public meeting to be held on February 1,2011.3.
 
On December 17, 2010, Defendants Chancellor of the City School District of theCity of New York (the “Chancellor”) and/or New York City Department of Education (“DOE”)published documents titled “Educational Impact Statement: The Proposed Co-location of a NewPublic Charter School, Success Academy Charter School, with Existing Schools in the BrandeisEducational Campus” (“EIS”), annexed hereto as Exhibit 1, and “Building Utilization Plan”(“BUP”), annexed hereto as Exhibit 2, relating to the Co-Location Proposal.4.
 
The EIS states,
inter alia
, “The DOE would renovate four rooms adjacent to thecurrent cafeteria to create a separate cafeteria for SACS students, who would be of elementary-school age.” Exhibit 1 at p. 3.5.
 
The EIS states,
inter alia
, that, “The high schools serve general educationstudents and students requiring special education services, including students currently enrolledin Collaborative Team Teaching (“CTT”) classes and students enrolled in Self-Contained (“SC”)classes. Upon admission, the schools work with parents to develop an individualized programthat reflects the resources that the schools can offer as appropriate for the student. Thus, servicesare tailored to meet the indivual (sic) needs of the students with disabilities currently enrolledand, as such, may vary from year to year.” Exhibit 1 at p. 3.6.
 
The EIS states “students classified as English Language Learners (“ELL”) areenrolled and receive English as a Second Language (“ESL”) or transitional bilingual services.All students enrolled in one of the schools in the Brandeis Campus will continue to receive their

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