Description of Alleged Discrimination

Summary:
Through this complaint, I will detail the manner in which Cortland County Administrator Robert Corpora and, by
extension, the Cortland County Legislature maintain an ongoing government policy of discrimination against private
citizens who outwardly affiliate with the First Amendment Auditor Creed.
It has been well documented by myself (Redress Now) and at least two other First Amendment Auditors based in the
Buffalo (Auditing Erie County) and Long Island (Long Island Audit) areas that Mr. Corpora has maintained an apparently
official government sign in the public waiting area directly outside his office in the Cortland County Office Building
located at 60 Central Avenue, Cortland, NY 13045. The sign exclaims “Everyone is Welcome Except First Amendment
Auditors”, and has been displayed from at least June 28, 2023 through August 7, 2023. For a significant portion of this
timeframe, the sign prominently displayed the official insignia of the Cortland County Mental Health Department. On
information and belief, Cortland County Director of Community Services Sharon MacDougall, who oversees the County
Mental Health Department, observed the offending sign outside Mr. Corpora’s office and consented to its continued
display. Hence, Ms. MacDougall is a party to this complaint.
The remainder of this document will outline how the government-sanctioned sign under review is discriminatory and
violates the New York State Human Rights Law (Executive Law Article 15) (https://dhr.ny.gov/Human-rights-law-
printable-pdf) which the New York State Division of Human Rights is tasked with enforcing. As such, the Division of
Human Rights is required by law to investigate the aforementioned government parties and hold them accountable to the
fullest extent of the law.

To settle this complaint, I will accept nothing less than the following:

1. Formal, individualized, and uniquely written letters from Cortland County Administrator Robert Corpora,
Cortland County Director of Community Services Sharon MacDougall, and all Cortland County Legislators
apologizing for posting and supporting the discriminatory sign under review. Said letters must be issued to me,
Dan Warmus, and Sean Paul Reyes.

2. A formal, written statement delivered by the New York State Division of Human Rights to Cortland County
Administrator Robert Corpora, Cortland County Director of Community Services Sharon MacDougall, and all
Cortland County Legislators sanctioning all of the aforementioned parties for posting the discriminatory sign
under review and for their ignorance of and flippant disregard for the First Amendment Civil Rights held by all
private citizens as well as the protections granted to the public by the New York State Human Rights Law. A
portion of said statement must explain why a government employee posting a personal opinion in the form of
official signage bearing official government insignia on the wall of a government office in a government building
while on the clock as a paid government employee does not qualify as First Amendment-protected free speech.

3. Written, formal guidance physically mailed by the New York State Division of Human Rights to all government
entities operating in New York State explaining in detail that, based on the arguments I make within this
complaint, First Amendment Auditors do qualify as a protected class within the meaning of the New York State
Human Rights Law and are thus entitled to all the protections afforded by said law. A copy of said guidance must
be emailed to sfelano@wtdcorp.com and physically mailed to P.O. Box 25, 7350 Erie Road, Derby, NY 14047.

Background:

It is beyond dispute that First Amendment Auditors, while controversial at times, have been solely responsible for forcing
the door of accountability open on events of substantial public importance that, if not for said Auditors, would have
remained shrouded in secrecy or vulnerable to official manipulation for lack of a clear and independent documentation of
what actually occurred. The infamous beating of Rodney King in 1991 (https://www.history.com/this-day-in-
history/police-brutality-caught-on-video), asphyxiation of Eric Garner in 2014 (https://project.wnyc.org/garner-
timeline/), and murder of George Floyd in 2020 (https://www.nytimes.com/2020/05/31/us/george-floyd-
investigation.html) are but several examples of illegal violence perpetrated by government agents that could have been

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hidden from public view if not for a private citizen – a First Amendment Auditor – exercising their right to video record in
public and disseminating what they saw to the world. While the government employees of Cortland County may claim
that video recording administrative employees in public is demonstrably different than video recording police in public
because the latter can use lethal force, I will point out that bad government police are often enabled by bad government
administrators, and thus recording one serves the same public interest as recording the other. Overall, First Amendment
Auditors step up and serve a vital function of public importance: securing the government transparency and accountability
required to maintain our Constitutional Republic.

No doubt, the Cortland County government officials named in this complaint will argue that First Amendment Auditors
are disruptive, harassing, illegitimate, a threat to safety, out to make money through YouTube advertising, and serve no
worthwhile purpose. However, said officials are actually using the aforementioned terms as euphemisms for personal
grievances that do not amount to any claim of significance supported by any law. Allow me to illustrate what I mean:

• Cortland County Government Employee Statement: “First Amendment Auditors are disruptive.”
o Translation: “First Amendment Auditors visit me at inconvenient times when I don’t feel that I look my
best, and that makes me feel bad.”

• Cortland County Government Employee Statement: “First Amendment Auditors are harassing.”
o Translation: “First Amendment Auditors confront me with a series of inconvenient questions that
demonstrate I, as a public employee, don’t understand that nation’s founding document, and I don’t like
that.”

• Cortland County Government Employee Statement: “First Amendment Auditors are illegitimate.”
o Translation: “First Amendment Auditors don’t conform with my traditional understanding of what a
journalist is or my belief that, in order to do certain things in public, you should be required to secure a
fee-based, subjective license from the government, and that makes me feel uncomfortable.”

• Cortland County Government Employee Statement: “First Amendment Auditors are a threat to safety.”
o Translation: “Even though First Amendment Auditors pass through stringent security measures upon
entering a government building and I have government police on speed-dial, I continue to harbor an
irrational belief that these Auditors will physically harm me in some way, and I want everyone to respect
and act on my irrational belief.”

• Cortland County Government Employee Statement: “First Amendment Auditors are only out to make money
through YouTube advertising.”
o Translation: “I don’t like that First Amendment Auditors use ingenuity and creative thinking to turn
their activism into a lucrative free market enterprise because it reminds me that I have settled for a rigid,
bureaucratic job where anyone with a camera can start asking me questions in a public space.”

• Cortland County Government Employee Statement: “First Amendment Auditors serve no worthwhile
purpose.”
o Translation: “Because I can draw no direct connection between a First Amendment Auditor’s public
accountability mission and my linear understanding of my daily government tasks, no one should
consider the purpose of First Amendment Auditors to be worthwhile.”

Note that each of the above grievances essentially amount to “I feel” statements and do not allege any violations of the
law that would preclude First Amendment Auditors from accessing public accommodations maintained by Cortland
County. If Cortland County employees truly believe that First Amendment Auditors are breaking the law when carrying
out their Constitutionally protected activities in public, they are more than welcome to summon the police to investigate
the matter. Instead of taking that approach, which would be the legal and proper way to handle such disputes, County
employees choose to gratify their personal emotions by posting official and discriminatory government signage that
offends the U.S. Constitution and violates the New York State Human Rights Law. Further, as outlined by the American
Civil Liberties Union (https://www.aclu.org/news/free-speech/arizonas-new-law-banning-people-from-recording-police-

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violates-our-first-amendment-rights): “Every federal circuit to consider the right to record – seven out of 13 circuits – has
held that this right clearly exists.” This is a legal consensus that Cortland County should respect.

Given the above and statements made to me by Cortland County employees, said employees are sure to assert that First
Amendment Auditors should be extended zero legal protections under the New York State Human Rights Law and that
government agents should be able to expel said Auditors from places of public accommodation by simply posting a
discriminatory sign with an official County logo on it. County employees have and will continue to make the ignorant
argument that “Free speech goes both ways”, essentially drawing a false equivalency between the free speech rights
guaranteed to a private citizen, and the made-up free speech protections that Cortland County officials attempt to conjure
out of thin air when they post official government signage professing a personal disdain for members of the First
Amendment Auditor Creed.

American Lawyer Top 100 law firm Haynes Boone aptly describes the Pickering Test
(https://www.haynesboone.com/news/publications/the-pickering-test-and-first-amendment-rights-of-government-
employees) that is applied to determine if speech promulgated by a government employee is, in fact, protected by the First
Amendment:

“To prove that the speech was protected, the employee must satisfy three requirements. First, the employee must have
spoken as a citizen and not in official capacity or in the exercise of government job responsibilities. Second, the speech
must have pertained to a matter of public concern, meaning a subject of general interest and value to the public – i.e., it
may not be a mere employee grievance. If these two requirements are satisfied, the court makes a third inquiry, balancing
the interests of the employee, as a citizen, “in commenting upon matters of public concern and the interests of the State, as
an employer, in promoting the efficiency of the public services it performs through its employees.” Pickering, 391 U.S. at
598. Only if the employee’s interest outweighs the employer’s does the employee state a viable claim.”

Clearly, the discriminatory sign that is the focal point of this complaint fails the Pickering Test. First, the government
employees that posted the sign most certainly did so in their official capacities and in the exercise of their government
responsibilities – that is why the sign was posted with an official Cortland County insignia on it outside a government
office in a government building by a government employee during the government workday. Second, the sign did not
reference a matter of public concern, but instead focused squarely on a government employee grievance.

Throughout all the First Amendment Audits referenced herein, not a single member of the public within any of the
Cortland County buildings reviewed complained about a First Amendment Auditor’s presence – hence, the public clearly
is not concerned about First Amendment Auditors operating within Cortland County buildings for the common benefit of
government accountability and transparency. However, numerous government employees did complain about the presence
of First Amendment Auditors across multiple visits. Notable examples are present within the video referenced later in this
complaint conducted by Auditing Erie County in June 2023. During this audit, County Administrator Corpora specifically
stated to the Auditor that government employees have complained to the Administrator’s Office about First Amendment
Audit activity.

Additionally, Auditing Erie County was harassed by multiple County employees simply because he was lawfully and
peacefully recording in a public space. This harassment by government employees came to a head in the parking lot of the
Cortland County Office Building when a County Social Services employee stopped her vehicle, rolled down her window,
and screamed at Auditing Erie County “Hey asshole! Video this!” She then presented her middle finger to the Auditor and
drove away. The sum total of this type of behavior by Cortland County government employees supports the clear
conclusion that the offending sign at the center of this complaint stems only from the unfounded personal grievances of
government employees and thus does not constitute speech pertaining to a matter of public concern, meaning a subject of
general interest and value to the public.

Given that the offending sign under review fails the first two elements of the Pickering Test, we need not entertain the
third and final element: whether or not the government employee’s interest in promulgating the speech of concern
outweighs the government employer’s interest in promoting the efficiency of the public services it performs through its
employees. However, for the sake of argument and illustration, the third element of the test will be entertained. The
offending sign most certainly fails the third and final element of the Pickering Test because, quite obviously, Cortland

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County’s interest in efficiently providing services to the public – with one such service being the opportunity for members
of the public to personally redress their grievances to government employees – is substantially hamstrung by the presence
of a discriminatory and offensive sign with an official County insignia on it that states “Everyone is Welcome Except First
Amendment Auditors.” This is evidenced by the First Amendment Audits outlined later in this complaint clearly showing
lawful, peaceful, and respectful attempts to video record in public and redress grievances to public officials. The presence
of the offending sign frustrated the ability of members of the public to accomplish the aforementioned activities, which
encompass the services provided by Cortland County to the public. Further, the presence of the offending sign, which
communicated an official policy of discrimination by virtue of the County insignia present on it, signaled to County
employees that it was acceptable and an officially sanctioned practice to deny members of the public outwardly affiliating
with the First Amendment Auditor Creed access to public accommodations, such as the County Administrator’s public
office, County reception overflow areas, the County Weights and Measures Department, and the County Mental Health
Department. Again, this is clearly demonstrated throughout the First Amendment Audits outlined later in this complaint.

Truly, what needs to be understood as background information for the purposes of this complaint is that the sign under
review serves as an exercise in personal emotional therapy for Cortland County employees. Said employees vehemently
defend their “right” to post such a sign in their official government capacity not because there is any corresponding
authorization to do so found within the U.S. Constitution or New York State Law, but because they are emotionally
struggling to accept the fact that the very nature of their public sector jobs has changed forever by virtue of a growing
segment of the public exercising their First Amendment right to video record in Cortland County buildings.

Clearly, County employees are unlawfully reconfiguring elements of their official duties (i.e. posting official signage) into
a public display of their psychological distress associated with the fact that the public has a legal right to video record
them and there is no legitimate way for the County to stop this activity. What Cortland County employees want is the best
of both worlds: public sector benefits and private sector privacy. But they can’t have both, at least not legally. To secure
the type of private sector privacy these public employees desire, they would have to leave their government positions in
favor of private sector employment. Rather than act like adults and embrace the latter option, they prefer to act out like
petulant school children over the fact that members of the public have the gall to confront them with this very rational
choice. What Cortland County employees would prefer is that citizens mortgage their First Amendment right to video
record to finance their public sector employment decisions. Best of luck to them on that mission.

For years, Cortland County employees have enjoyed stable government employment and generous public sector pay and
benefits with the added perk of remaining largely anonymous and free from public scrutiny within the confines of various
county buildings. Indeed, according to GovSalaries.com (https://govsalaries.com/corpora-robert-147687436) Mr.
Corpora’s total 2022 pay was $126,517. This salary is 157% higher than average and 166% higher than the median salary
in Cortland. Ms. MacDougall’s total 2022 pay was $96,960. According to GovSalaries.com
(https://govsalaries.com/mac-dougall-sharon-147693830), this salary is 97% higher than average and 104% higher than
the median salary in Cortland.

I invite any objective observer to search the entirety of Cortland County for private sector positions offering comparable
pay to what was outlined above. I’ll save you the trouble – they are few and far between. Why? Because Cortland County
government has done an abysmal job of making the County a welcoming and sustainable place to grow a private sector
business. When I travel across Cortland County, the majority of what I see is poorly maintained roads, shuttered
businesses, and regular people struggling to simply achieve the basic necessities of daily living. Contrast that with the
opulent compensation enjoyed by Mr. Corpora and Ms. MacDougall and the picture of what Cortland County is comes
into clear focus: The area is a case-study in public-sector feudalism. There are the County employees that apparently
control access to public accommodations at their sole discretion (as evidenced by the offending sign outlined in this
complaint) and enjoy pay and benefits far out of step with what is normal for the County, and then there are the rest of us
serfs who are expected to come begging for the economic scraps that remain and grovel before County officials to obtain
simple access to public buildings paid for by our tax dollars. Wealth accumulation is a one-way street in Cortland County:
it flows out of the pockets of taxpayers and directly into the pockets of County employees who then determine – based on
their personal prejudice against members of certain creeds – who can and cannot access County buildings that taxpayer
dollars built and maintain! No doubt, Russia’s Vladimir Putin and China’s Xi Jinping would beam with pride upon
learning how Cortland County is run given that both autocrats manage their fiefdoms in similar fashion.

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It is time to hold Cortland County Administrator Robert Corpora, Cortland County Director of Community Services
Sharon MacDougall, and the full Cortland County Legislature accountable for their official policy of discrimination
against members of the First Amendment Auditor Creed. Failure to promptly do so will likely produce a visceral and
negative reaction from the general public culminating in a wave of negative media exposure that could last months if not
years. I implore the New York State Division of Human Rights to review the definitions, chronology of events, and
concluding thoughts contained in the remainder of this document and take immediate action on the complaint contained
herein.

Definitions:
Section 292 (https://dhr.ny.gov/292-definitions) of the Human Rights Law states:
“The term ‘place of public accommodation, resort or amusement’ shall include, regardless of whether the owner or
operator of such place is a state or local government entity or a private individual or entity, except as hereinafter
specified, all places included in the meaning of such terms as:… agencies or bureaus; public halls, public rooms, public
elevators, and any public areas of any building or structure...”
Surely the Courtland County Office Building and the Cortland County Mental Health Department Building are captured
within the meaning of the above. The vast majority of both government buildings contain or should contain “agencies or
bureaus; public halls, public rooms, public elevators, and any public areas of any building or structure.”
Further, while Section 292 defines the meanings of terms like “disability”, “predisposing genetic characteristic”,
“pregnancy-related condition”, “familial status”, “sexual orientation”, and “military status”, among others, it fails to
define the term “creed.” The Division of Human Rights Public Accommodation Complaint Form
(https://dhr.ny.gov/fillable-public-accommodation-complaint-form) defines “creed” as:
“Creed / Religion (religious membership, belief, practice, or observance; or discrimination because you do not have a
religious belief)”
However, a definition included on a complaint form does not hold the force of law. New York State Human Rights Law
does hold the force of law. Hence, given that the law under which the Division of Human Rights operates does not define
the term “creed”, one must turn to plainly understood definitions of said term that are present in common dictionaries,
such as:
From Merriam-Webster (https://www.merriam-webster.com/dictionary/creed): “1.) A brief authoritative formula of
religious belief. 2.) A set of fundamental beliefs. Also: a guiding principle”

From Cambridge Dictionary (https://dictionary.cambridge.org/us/dictionary/english/creed): “A set of beliefs that

influences the way you live.”

From Dictionary.com (https://www.dictionary.com/browse/creed): “1.) Any system, doctrine, or formula of religious

belief, as of a denomination. 2.) Any system or codification of belief or of opinion.”

From Collins Dictionary (https://www.collinsdictionary.com/us/dictionary/english/creed): “A creed is a set of beliefs,

principles, or opinions that strongly influence the way people live or work.”

Clearly, all of the above dictionary definitions support interpretations of the term “creed” that stand disconnected from
religious beliefs and/or practices. Likewise, these definitions buttress the assertion that a private citizen need not maintain
a set of beliefs, principles, or influencing opinions specifically predicated on religion in order to validly claim protection
from discrimination under the New York State Human Rights Law. Additionally, the Division of Human Rights states on
its website (https://dhr.ny.gov/new-updates-human-rights-law) that, effective August 12, 2019, “The Human Rights Law
is to be liberally construed, under New York State law, without reference to any federal law that may lead to a more
restrictive result.” Surely, liberally construing the Human Rights Law supports the definition of “creed” outlined within
this complaint.
Under the plain meaning and common understanding of the term “creed” as outlined by numerous dictionaries, state
Human Rights Law protections must be extended to First Amendment Auditors even if said Auditors are not operating

5
under a belief system directly connected to religion. The fact that First Amendment Auditors clearly operate under a
system or codification of belief or of opinion focused on securing government transparency and accountability under the
First Amendment of the U.S. Constitution most certainly qualifies them for protection from discrimination under the state
Human Rights Law. It likewise secures them a guarantee of enthusiastic and unbiased investigation by the Division of
Human Rights of their allegations of discrimination at the hands of government entities and officials.
Further, even if the Division of Human Rights were obligated to honor the religion-affiliated definition of “creed”
provided on the agency’s Public Accommodation Complaint Form in order to lawfully trigger an investigation into an
allegation of discrimination, and I vehemently deny that this is the case, my complaint contained herein satisfies such a
definition. It satisfies a religion-based understanding of “creed” because my longstanding faith as a practicing Christian
necessitates my First Amendment Audit activity. In other words, I view it as my Christian duty and a religious service to
hold the secular government accountable via First Amendment Audits. Many other Christians who participate in First
Amendment Audits share the same belief – that we are compelled by Jesus Christ’s example to closely monitor our
government and hold its officials accountable.
As outlined in Clifford J. Durr’s Jesus Christ As A Free Speech Victim
(https://www.crmvet.org/info/6008_eclc_durr_jesus.pdf), a text I studied as part of my early Christian education and one
to which I often return, Jesus Christ was condemned to die on the Cross by feckless government officials largely due to
the free speech he exercised against said officials. As Mr. Durr recounts in his publication:
“The theological emphasis upon the supernatural elements of the Crucifixion and Resurrection have served to obscure a
very significant aspect of the whole affair. Here was a typical civil liberties case with the issue of freedom of speech,
opinion, worship, and of ‘due process of law’ directly involved. The victim only was unique. The other characters involved
belonged to no particular race, creed, or period of history.”
“Jesus’ appeal was to the ‘malcontents,’ and he was effective in stirring them up and in gaining followers in ever
increasing numbers. He effectively challenged the status quo. In other words, he was ‘subversive’ in the truest sense of the
term; as the chief priests put it, he was ‘perverting the nation’ by his teaching. He was a ‘dangerous’ influence, and he
had to be stopped.”

“Jesus was not one to betray his friends. He silently refused to expose his associates and immediately forced the trial into
the issue of freedom of speech: ‘I spake openly to the world, I ever taught in the synagogue, and in the temple, whither the
Jews always resort; and in secret have I said nothing.’ ‘Why askest thou me? Ask them which heard me, what I have said
unto them; behold, they know what I said.’ He knew the law and stood on his right not to incriminate himself.”

As outlined by Mr. Durr, Jesus Christ is a free speech martyr. Faithful Christians must follow his example to protect and
defend the God-given right to free speech that predates all governments and exists outside the reach of all governments.
This view is endemic to true Christian teachings, and it is the religious belief that I and many other Christian First
Amendment Auditors hold. Hence, I engage in First Amendment Audit activity because my Christian teachings compel
me to. Therefore, the discrimination allegation contained herein satisfies both secular and religious interpretations of the
term “creed”.

Section 296 (https://www.nysenate.gov/legislation/laws/EXC/296) of the Human Rights Law outlines the unlawful
discriminatory practices that the Division of Human Rights must investigate and rectify. More specifically, Section 296
states:
“It shall be an unlawful discriminatory practice for any person, being the owner, lessee, proprietor, manager,
superintendent, agent or employee of any place of public accommodation, resort or amusement, because of the race,
creed, color, national origin, citizenship or immigration status, sexual orientation, gender identity or expression, military
status, sex, disability, marital status, or status as a victim of domestic violence, of any person, directly or indirectly, to
refuse, withhold from or deny to such person any of the accommodations, advantages, facilities or privileges thereof,
including the extension of credit, or, directly or indirectly, to publish, circulate, issue, display, post or mail any written or
printed communication, notice or advertisement, to the effect that any of the accommodations, advantages, facilities and
privileges of any such place shall be refused, withheld from or denied to any person on account of race, creed, color,
national origin, citizenship or immigration status, sexual orientation, gender identity or expression, military status, sex,
disability or marital status, or that the patronage or custom thereat of any person of or purporting to be of any particular

6
race, creed, color, national origin, citizenship or immigration status, sexual orientation, gender identity or expression,
military status, sex or marital status, or having a disability is unwelcome, objectionable or not acceptable, desired or
solicited.”

As noted previously, the Courtland County Office Building and the Cortland County Mental Health Department Building
are captured within the meaning of ‘place of public accommodation, resort or amusement’ as defined by the Human
Rights Law. Clearly, County Administrator Robert Corpora and County Director of Community Services Sharon
MacDougall qualify as managers, superintendents, agents and/or employees of both places of public accommodation. As
demonstrated above, I and other First Amendment Auditors meet both secular and religious definitions of the term “creed”
as understood within the confines of the Human Rights Law, and thus I and other First Amendment Auditors are entitled
to the protections of said law.

As summarized above and as will be detailed below, Mr. Corpora and Ms. MacDougall are complicit in directly or
indirectly refusing, withholding from, or denying to myself as a member of the First Amendment Auditor Creed, any of
the accommodations, advantages, facilities, or privileges of the places of public accommodation managed by either or
both. Further, Mr. Corpora and Ms. MacDougall are complicit in directly or indirectly publishing, circulating, issuing,
displaying, or posting any written or printed communication, notice or advertisement, to the effect that any of the
accommodations, advantages, facilities, and privileges of any such place of public accommodation that either or both
manage shall be refused, withheld from, or denied to any person on account of creed – more specifically, the First
Amendment Auditor Creed. Finally, Mr. Corpora and Ms. MacDougall are complicit in communicating via official
government signage that patronage by any person of or purporting to be of any particular creed – specifically, the First
Amendment Auditor Creed – at the places of public accommodation managed by either or both is unwelcome,
objectionable, not acceptable, not desired, or not solicited. Thus, Mr. Corpora, Ms. MacDougall and, by extension, the
Cortland County Legislature have clearly violated the New York State Human Rights Law and must therefore be
investigated by the Division of Human Rights and held accountable to the fullest extent of the law.

Chronology of Events:

It has been well documented by myself (Redress Now) and at least two other First Amendment Auditors based in the
Buffalo and Long Island areas that Cortland County Administrator Robert Corpora has maintained an official government
sign in the public waiting area directly outside his office in the Cortland County Office Building located at 60 Central
Avenue, Cortland, NY 13045. The sign exclaims “Everyone is Welcome Except First Amendment Auditors”, and has been
displayed from at least June 28, 2023 through August 7, 2023.
This sign was first documented by Dan Warmus of Auditing Erie County on or about Wednesday, June 28, 2023. Below is
an image depicting the sign as it appeared on the aforementioned date. Take note of the presence of the official insignia of
the Cortland County Mental Health Department at the top of the sign, indicating a policy endorsed by the County
Administrator and Cortland County Director of Community Services Sharon MacDougall of refusing taxpayer-funded
mental health services to First Amendment Auditors:

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Below is the official insignia of the Cortland County Mental Health Department, shown on the official County Mental
Health Department website (https://www.cortland-co.org/453/Horizon-House). Said insignia is conspicuously present on
the discriminatory sign posted by County Administrator Corpora as pictured above:

Video review of the above sign by Dan Warmus of Auditing Erie County on or about Wednesday, June 28, 2023 can be
viewed at the below link. The sign appears at the 56 minute 36 second mark of the recording:
https://www.youtube.com/watch?v=0NWMRdyYM30
Following the lawful First Amendment Audit by Mr. Warmus in late June 2023, Sean Paul Reyes of Long Island Audit
lawfully and respectfully visited Mr. Corpora’s office to question him about the offensive and divisive nature of the
“Everyone is Welcome Except First Amendment Auditors” sign. Mr. Reyes visited the office on or about Wednesday,
August 2, 2023. By this date, Mr. Corpora had apparently altered the sign by placing an “I LOVE NY” patch atop it to
obscure the Cortland County Mental Health Department insignia that was present in late June 2023. An image depicting
the sign as it appeared on August 2, 2023 is below:

Video review of the above sign by Sean Paul Reyes of Long Island Audit on or about Wednesday, August 2, 2023 can be
viewed at the below link. The sign appears at the 2 minute 4 second mark of the recording:
https://www.youtube.com/watch?v=Jo60M4dwdmc
Mr. Corpora’s use of the I LOVE NY insignia to apparently obfuscate the County Mental Health Department insignia
created a new problem set for himself and his employer: Courtland County. The I LOVE NY insignia is actually a
trademark held by New York State Department of Economic Development (Empire State Development) and, as shown
above, appears to communicate endorsement of an anti-First Amendment message by the I LOVE NY brand and, by
extension, Empire State Development. Further, the I LOVE NY brand website (https://www.iloveny.com/licensee-info/)
8
maintained by Empire State Development clearly states that “Use of the I LOVE NY trademarks requires prior
approval by the New York State Department of Economic Development and a valid license agreement.”
Mr. Corpora has stated directly to me that he has not sought the proper approval or licensing from Empire State
Development to include the I LOVE NY trademark on his discriminatory signage. Thus, I emailed Empire State
Development Deputy General Counsel Goldie Weixel and other related parties on Tuesday, August 8, 2023 at 4:55 PM to
make them aware of the issue. That email chain is attached to this document. This issue relevant to disregard of state
policy as it concerns trademarks held by state agencies being posted on discriminatory signage without the requisite
approval is offered because it demonstrates the likelihood of Mr. Corpora’s poor judgement concerning other strictures
that are binding on him as a government employee. Such strictures include respect for the First Amendment rights of
private citizens and the healthy restraint that is required when it comes to display of personal opinions in an official,
government capacity.
Following the lawful First Amendment Audit by Mr. Reyes in early August 2023, I (Redress Now) lawfully and
respectfully visited Mr. Corpora’s office to question him about the offensive and divisive nature of the “Everyone is
Welcome Except First Amendment Auditors” sign. I visited the office at about 11 AM on Monday, August 7, 2023. By this
date, Mr. Corpora had apparently altered the sign further by physically cutting the Cortland County Mental Health
Department insignia out of the sign and again placing the “I LOVE NY” patch atop it. An image that I captured depicting
the sign as it appeared on August 7, 2023 is below. Note the rectangular shape flanking the I LOVE NY insignia at the top
of the sign formed by the exposed corkboard now visible because the County Mental Health Department insignia had
been physically cut away. Clearly, the fact that Mr. Corpora, Ms. MacDougall, or a County employee under the direction
of either or both took the time to physically remove an official County insignia from this sign after visits from two First
Amendment Auditors indicates that Mr. Corpora and/or Ms. MacDougall were aware that such signage does not constitute
First Amendment-protected free speech and thus created legal liability for themselves and Cortland County. That concern
is correct:

Video review of the above sign by myself (Redress Now) on Monday, August 7, 2023 is in the process of being publicly
released to the YouTube channel under the @RedressNow handle and will be available for review at the following channel
location: https://www.youtube.com/@RedressNow
Immediately upon my arrival at his office door, Mr. Corpora sarcastically mumbled “Ooooh great….” and attempted to
ignore my presence. He went on to articulate his disdain for First Amendment Auditors and employed what I believe to be
a fabricated “off-site meeting” and office security procedure to eject me from his public office in direct contravention of
my First Amendment civil right to peacefully redress a public official. Overall, due to my outward affiliation with the First
Amendment Auditor Creed as outlined in this complaint, I sincerely believe Mr. Corpora purposefully posted the
9
“Everyone is Welcome Except First Amendment Auditors” sign referenced herein to communicate an official policy to
me, government employees, and other members of the public that First Amendment Auditors like me are not welcome to
access the taxpayer-funded accommodations on Cortland County public property that are freely available to everyone else.
To further make his point, I sincerely believe Mr. Corpora lied to my face about having an “off-site meeting” to attend so
that he could directly withhold my access to his office and thus avoid participating in a civil conversation about a matter I
believed to be of public import under his direct control. Obviously, access to a public office for the purpose of holding
such a civil conversation with a public official regarding a matter of redress is a form of public accommodation open to
any other member of the public. However, in Cortland County, such accommodation is only open to a member of the
public so long as they do not identify as a First Amendment Auditor.
I have submitted a Freedom of Information Law (FOIL) request to Cortland County (attached to this complaint) seeking
all documentation of Mr. Corpora’s schedule for the date of Monday, August 7, 2023 to determine if he did, in fact,
fabricate a meeting to create a backdoor method of ejecting me from his office without being required to contact law
enforcement officers in an attempt to unlawfully trespass me from a public building.

Conclusion:

Throughout this complaint, I have detailed the manner in which Cortland County Administrator Robert Corpora and, by
extension, the Cortland County Legislature maintain an ongoing government policy of discrimination against private
citizens who outwardly affiliate with the First Amendment Auditor Creed.
It has been well documented by myself (Redress Now) and at least two other First Amendment Auditors based in the
Buffalo (Auditing Erie County) and Long Island (Long Island Audit) areas that Mr. Corpora has maintained an apparently
official government sign in the public waiting area directly outside his office in the Cortland County Office Building
located at 60 Central Avenue, Cortland, NY 13045. The sign exclaims “Everyone is Welcome Except First Amendment
Auditors”, and has been displayed from at least June 28, 2023 through August 7, 2023. For a significant portion of this
timeframe, the sign prominently displayed the official insignia of the Cortland County Mental Health Department. On
information and belief, Cortland County Director of Community Services Sharon MacDougall, who oversees the County
Mental Health Department, observed the offending sign outside Mr. Corpora’s office and consented to its continued
display. Hence, Ms. MacDougall is a party to this complaint.
To be clear, a First Amendment Audit conducted by WNY AUDITS of the Cortland County Office Building on or about
Thursday, August 10, 2023 revealed that the offending sign discussed in this complaint had apparently been removed as of
that date. An image depicting the signboard maintained by Mr. Corpora where the discriminatory sign previously appeared
is shown below. Note that “How to Promote a Safe Workplace” signage has been posted in place of the offending sign:

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This can be viewed at the 21 minute 16 second mark of the WNY AUDITS recording:
https://www.youtube.com/watch?v=o0foBlr2WX0&t=1s
While the confirmed removal of the offending and discriminatory sign is a laudable outcome, this development should not
halt the Division of Human Rights from investigating this matter further and sanctioning Mr. Corpora, Ms. MacDougall,
and the Cortland County Legislature in an effort to stop similar discriminatory signage from being generated in the future.
To illustrate why this is the case, I’d like to point out that the U.S. Supreme Court is guided by what is called the
“Mootness Doctrine.” Said Doctrine serves as a limitation on the power of judicial review granted to the federal courts.
Essentially, courts may only get involved in disputes that are ongoing – but it has been up to the Supreme Court to
determine what that means.
While it may be tempting to declare that the dispute over Mr. Corpora’s offending sign has ended because the sign has
been removed, it would be an error to arrive at that conclusion. What Mr. Corpora and, by extension, the Cortland County
Legislature has engaged in by removing the sign is something called “Voluntary Cessation” – one of the exceptions to the
Mootness Doctrine. The Supreme Court has held that a party’s “voluntary cessation” of an unlawful practice will usually
not moot its opponent’s challenge to that practice. Thus, “a defendant cannot automatically moot a case by simply ending
its unlawful conduct once sued.” This exception to the Mootness Doctrine exists because if a litigant could defeat a
lawsuit simply by temporarily ceasing its unlawful activities, there would be nothing to stop that litigant from engaging in
that unlawful behavior again after the court dismissed the case. The litigant would effectively “be free to return to [its] old
ways.” And so it is with Mr. Corpora, Ms. MacDougall, and the Cortland County Legislature. The Division of Human
Rights must vigorously investigate them to ensure the bad actors do not continue their bad behavior.
In conclusion, this document has outlined in great detail how the government-sanctioned sign under review is
discriminatory and violates the New York State Human Rights Law (Executive Law Article 15)
(https://dhr.ny.gov/Human-rights-law-printable-pdf) which the New York State Division of Human Rights is tasked with
enforcing. As such, the Division of Human Rights is required by law to investigate the aforementioned government parties
and hold them accountable to the fullest extent of the law.

As stated earlier, to settle this complaint, I will accept nothing less than the following:

1. Formal, individualized, and uniquely written letters from Cortland County Administrator Robert Corpora,
Cortland County Director of Community Services Sharon MacDougall, and all Cortland County Legislators
apologizing for posting and supporting the discriminatory sign under review. Said letters must be issued to me,
Dan Warmus, and Sean Paul Reyes.

2. A formal, written statement delivered by the New York State Division of Human Rights to Cortland County
Administrator Robert Corpora, Cortland County Director of Community Services Sharon MacDougall, and all
Cortland County Legislators sanctioning all of the aforementioned parties for posting the discriminatory sign
under review and for their ignorance of and flippant disregard for the First Amendment Civil Rights held by all
private citizens as well as the protections granted to the public by the New York State Human Rights Law. A
portion of said statement must explain why a government employee posting a personal opinion in the form of
official signage bearing official government insignia on the wall of a government office in a government building
while on the clock as a paid government employee does not qualify as First Amendment-protected free speech.

3. Written, formal guidance physically mailed by the New York State Division of Human Rights to all government
entities operating in New York State explaining in detail that, based on the arguments I have made within this
complaint, First Amendment Auditors do qualify as a protected class within the meaning of the New York State
Human Rights Law and are thus entitled to all the protections afforded by said law. A copy of said guidance must
be emailed to sfelano@wtdcorp.com and physically mailed to P.O. Box 25, 7350 Erie Road, Derby, NY 14047.

According to the complaint forms provided on the File A Complaint (https://dhr.ny.gov/complaint) page of the Division
of Human Rights website, a complaint must be filed within one year of the most recent act of alleged discrimination in
order to be properly investigated. Please note that this complaint is being filed a mere 10 days after the date of the most
recent act of alleged discrimination and thus easily qualifies for timely review.

11
Further, I am aware of the following investigative procedure that the Division of Human Rights is obligated to pursue as
outlined on the File A Complaint (https://dhr.ny.gov/complaint) page of the Division’s website. Be advised that I intend to
make full use of this procedure and all relevant methods of appeal:

“Once a regional office receives your complaint the investigation by the Division of Human Rights will begin.

1. The first step will be to notify the respondent(s). A respondent is a person or entity who you believe discriminated
against you.
2. Next, the Division will resolve any questionable issues of jurisdiction.
3. If applicable, a copy of your complaint will be forwarded to the U.S. Equal Employment Opportunity Commission
(EEOC) or the U.S. Department of Housing and Urban Development (HUD).
4. An investigation will be conducted using methods like written inquiry, field investigation and investigatory
conference.
5. In most cases the investigation will be completed within 180 days.

Once the investigation is complete, the Division will determine if there is probable cause that an act of discrimination has
occurred, and will notify the complainant and respondent in writing.

If there is a finding of no probable cause, or lack of jurisdiction, the matter is dismissed. A complainant may appeal to the
State Supreme Court within 60 days.

If it is determined that there is probable cause your case will be presented in a public hearing. Visit our public hearing
section to learn more about that process.

If there is a Determination of no probable cause, lack of jurisdiction, or any other type of dismissal of the case, the
Complainant may appeal to the State Supreme Court within 60 days.

If the Determination is one of probable cause, there is no appeal to court. The case then proceeds to public hearing before
an Administrative Law Judge. Under Rule 465.20 (9 N.Y.C.R.R. § 465.20), the Respondent may ask the Commissioner of
Human Rights within 60 days of the finding of probable cause to review the finding of probable cause. Such application
should be sent to the General Counsel of the Division and to the Complainant, and Complainant’s attorney, if any.

Please take further notice that in the alternative to the right to appeal noticed above, in cases alleging housing
discrimination only, a person whose complaint has been dismissed by the New York State Division of Human Rights after
investigation for lack of jurisdiction or lack of probable cause may file the same cause of action in a court of appropriate
jurisdiction pursuant to this section, unless appeal to the New York State Supreme Court as stated above has been
sought.”

I expect a speedy investigation of this matter and timely updates on progress. Please contact me via email at
sfelano@wtdcorp.com to gather additional information and advise on next steps.

Thursday, August 17, 2023

Steve Felano
Redress Now

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EMPIRE STATE DEVELOPMENT EMAIL CHAIN
Stephen Felano

From: Stephen Felano

Sent: Tuesday, August 8, 2023 4:55 PM
To: Goldie.Weixel@esd.ny.gov
Cc: globalny@esd.ny.gov; nys-centralny@esd.ny.gov; nys-southerntier@esd.ny.gov;
shempstead@cortland-co.org; pdawson@cortland-co.org; dbentley@cortland-co.org;
bharbin@cortland-co.org; cbischoff@cortland-co.org; rvandee@cortland-co.org; swilson@cortland-
co.org; rstock@cortland-co.org; alhomer@cortland-co.org; kfitch@cortland-co.org; ljones@cortland-
co.org; kpreston@cortland-co.org; cnewell@cortland-co.org; jnauseef@cortland-co.org;
ewaldbauer@cortland-co.org; sprice@cortland-co.org; gwagner@cortland-co.org;
pheider@cortland-co.org; mdeccleston@cortland-co.org; Auditing Erie County;
LongIslandAudit@gmail.com; TBennett@cortlandvoice.com; news@nc34.com;
egeibel@cortlandstandard.com; tmcadam@cortlandstandard.com; kconlon@cortlandstandard.com;
lbyrne@cortlandstandard.com; jmack@cortlandstandard.com; mmellott@cortlandstandard.com;
James Ostrowski; vjmonty@cortland-co.org; administrator@cortland-co.org;
duanewhitmer@yahoo.com
Subject: Offensive Use of I LOVE NY Trademark in Cortland County

Good afternoon Ms. Weixel,

Given your role as Deputy General Counsel at Empire State Development, I am contacting you regarding what I believe
to be unlicensed use of the I LOVE NY trademark on an offensive and discriminatory sign placed by Cortland County
Administrator Robert Corpora in the public waiting area directly outside his office in the Cortland County Office Building
located at 60 Central Avenue, Cortland, NY 13045. Below is an image of the sign collected outside Mr. Corpora’s office at
11 AM on Monday, August 7, 2023:

1
The sign exclaims, seemingly on behalf of the Cortland County Government, that “Everyone is Welcome Except First
Amendment Auditors.” Additionally, the sign is adorned with the I LOVE NY trademark held by New York State
Department of Economic Development and, as shown above, appears to communicate endorsement of the anti-First
Amendment message by the I LOVE NY brand and, by extension, your office.
In addition to my own direct observation of this sign on Monday, August 7, 2023 at 11 AM, the presence of this sign has
been documented within the past two months by two additional First Amendment Auditors via the videos linked below:

 Auditing Erie County

 Long Island Audit

Given that New York State has expressly protected and thus endorsed the concept of regular citizens recording public
officials via passage of the “Right to Record Act” in 2020, it appears highly contradictory and unlikely that the I LOVE NY
brand and, by extension, New York State Department of Economic Development would endorse a sign stating “Everyone
is Welcome Except First Amendment Auditors.” However, on the I LOVE NY brand website maintained by your office, it
is clearly stated that:
“Use of the I LOVE NY trademarks requires prior approval by the New York State Department of Economic
Development and a valid license agreement.”
Hence, I am contacting you to both make you aware of the use of the I LOVE NY trademark on the aforementioned
offensive sign and ask directly:
Did Cortland County Administrator Robert Corpora receive express approval from New York State Department of
Economic Development to incorporate the I LOVE NY trademark into the offensive and discriminatory sign he
knowingly posted as a public official in a public area of a county government building? Additionally, does Mr. Corpora
2
hold a valid license agreement from New York State Department of Economic Development to utilize the
aforementioned trademark in said offensive manner? If Mr. Corpora did not receive express approval and a valid
license agreement as required by policy, what damages/penalties may be imposed upon him and potentially the
county that employs him? Will New York State Department of Economic Development request that Mr. Corpora
remove the I LOVE NY trademark from his offensive sign?
Thank you for your prompt attention to this matter.

All the best,

Steve Felano
Redress Now

3
Stephen Felano

From: Stephen Felano

Sent: Tuesday, August 8, 2023 7:24 PM
To: Linda Jones
Cc: globalny@esd.ny.gov; nys-centralny@esd.ny.gov; nys-southerntier@esd.ny.gov;
shempstead@cortland-co.org; pdawson@cortland-co.org; dbentley@cortland-co.org;
bharbin@cortland-co.org; cbischoff@cortland-co.org; rvandee@cortland-co.org; swilson@cortland-
co.org; rstock@cortland-co.org; alhomer@cortland-co.org; kfitch@cortland-co.org;
kpreston@cortland-co.org; cnewell@cortland-co.org; jnauseef@cortland-co.org;
ewaldbauer@cortland-co.org; sprice@cortland-co.org; gwagner@cortland-co.org;
pheider@cortland-co.org; mdeccleston@cortland-co.org; Auditing Erie County;
LongIslandAudit@gmail.com; TBennett@cortlandvoice.com; news@nc34.com;
egeibel@cortlandstandard.com; tmcadam@cortlandstandard.com; kconlon@cortlandstandard.com;
lbyrne@cortlandstandard.com; jmack@cortlandstandard.com; mmellott@cortlandstandard.com;
James Ostrowski; vjmonty@cortland-co.org; administrator@cortland-co.org;
duanewhitmer@yahoo.com; Franklin Ruttan; Goldie.Weixel@esd.ny.gov
Subject: RE: Offensive Use of I LOVE NY Trademark in Cortland County

Ms. Jones,

I appreciate the reply. That news is encouraging, yet irrelevant to the issue at hand. The fact that the sign has been
removed (apparently as of today given that I directly observed the sign yesterday) does not remedy the evasion of prior
approval and licensing as required by Empire State Development (ESD) policy – I’m sure Ms. Wiexel will agree.

It has been well documented that Mr. Corpora has maintained the “All are Welcome Except First Amendment Auditors”
sign in front of his county office with the I LOVE NY trademark affixed from at least June 28, 2023 through August 7,
2023. Hence, whatever penalty has been assessed by ESD against other entities that have displayed the I LOVE NY
trademark without the required approvals and licensing for 30 days or more in the past must now be applied to Mr.
Corpora/Cortland County. No doubt, records of the past application of such penalty and against whom can be accessed
via voluntary disclosure by ESD, FOIL request to ESD, an Article 78 proceeding against ESD, and/or discovery tied to other
legal proceedings involving ESD. I’m sure Ms. Wiexel and others at ESD will greatly appreciate the difficult position you
and other county leaders are putting them in because you choose to continue employing a county administrator who
can’t think five inches in front of his face before he does something in extremely poor judgement for
personal/emotional gratification.

In any event, if such penalty is not assessed against Mr. Corpora/Cortland County by ESD, I will most certainly seek out
all private and public entities statewide to make them aware that they are apparently no longer required to seek prior
approval or a licensing agreement from ESD to make use of the I LOVE NY trademark in their marketing and signage.

Further, if it turns out that ESD will not apply the same penalties to Mr. Corpora/Cortland County that have been or
would be applied to others for disregard of the I LOVE NY trademark and licensing requirements, obviously that would
permit any number of persons or entities to display said trademark at the top of any number of similarly offensive signs
targeting any number of other “controversial” professions. Just think of the possibilities:

“Everyone is Welcome Except Abortion Doctors”

“Everyone is Welcome Except Migrant Resettlement Coordinators”
“Everyone is Welcome Except LGBTQ+ Advocates”
“Everyone is Welcome Except Catholic Priests”
“Everyone is Welcome Except Men’s Rights Advocates”
1
“Everyone is Welcome Except Gay Conversion Therapists”

I can think of a number of town and county leaders across Upstate New York that would happily display such signage
right outside their government office with the I LOVE NY trademark prominently affixed just as Mr. Corpora has done
for at least the last month as it relates to First Amendment Auditors. Mr. Corpora fails to understand that the time,
place, and manner in which he displayed his sign and the trademark affixed results in zero First Amendment
protection given his role as a government official. Government employees that have acted similarly under analogous
circumstances (i.e. expressed a personal opinion while on the clock as a government employee, in a government
office, in a government building in such a manner that subordinates and the public could reasonably be led to believe
that said opinion is actually government policy) have been disciplined and/or terminated for this very reason. I can
send you the examples.

Perhaps I will rent out the closest billboard to the Governor’s Mansion in Albany and have Lamar Advertising install a
sign – with the I LOVE NY trademark prominently displayed – that says “All are Welcome Except Hochul Administration
Staffers”. I bet that would go over great. Well, if ESD fails to sanction Mr. Corpora/Cortland County, I would certainly
have precedent to take such an action with zero protest, sanction, or recourse from ESD or any other New York State
official, legislative body, or agency.

You have a problem in Cortland County named Robert Corpora. I suggest you and the remainder of the County
Legislature fix that problem. First Amendment Auditors will return to confirm the offending sign has, in fact, been
removed and to conduct additional, lawful audit activity. Adjusted behavior from Mr. Corpora and other government
staff will be expected (this includes the social services employee who flipped off my colleague from Erie County for doing
nothing more than recording a simple walk down a public hallway).

Best,

Steve Felano
Redress Now

From: Linda Jones <ljones@cortland-co.org>

Sent: Tuesday, August 8, 2023 5:38 PM
To: Stephen Felano <sfelano@wtdcorp.com>
Subject: Re: Offensive Use of I LOVE NY Trademark in Cortland County

Stephen,

That sign has been removed.

LINDA JONES
DISTRICTLD9

This email, including attachments, may include confidential and/or proprietary information and is intended for persons sent
2
to only. If the reader of this email is not the intended recipient or his or her authorized agent, the reader is hereby notified
that any dissemination, distribution, or copying of this email is prohibited. If you have received this email in error, please
notify the sender by replying to this message and deleting this email immediately.

3
FOIL REQUEST TO CORTLAND COUNTY