SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK __________________________________________ ) TANYA ACEVEDO, ) Index No. _____________ individually and as parent and next friend ) of A.A., a minor child; and ) ) THE ) KING’S CHOICE LEAH, ) Plaintiffs, ) vs. ) COMPLAINT AND ) DEMAND FOR NEW YORK CITY DEPARTMENT OF ) JURY TRIAL EDUCATION; ) ) WILLIAM HARRINGTON, ) in his official capacity as ) Director of the New York City ) Central Office of Home Schooling; ) ) CARMEN FARINA, ) in her official capacity as ) Schools Chancellor of New York City; and ) ) ELIZABETH ROSE, ) in her official capacity as Deputy Schools ) Chancellor for Operations, New York City, ) ) ) Defendants. __________________________________________) Plaintiffs Tanya Acevedo, and LEAH, by and through counsel, allege The King’s Choice upon information and belief the following against Defendants. INTRODUCTION The New York City Department of Education (also known as the York City “New Board of the York City Panel for Education the operation Education” or “New Policy”) oversees of New York thirty-four (34) school districts, as well as the New York City Central Office City’s of Homeschooling. The Department is managed by Defendant Carmen Farina, in her official
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK __________________________________________ ) TANYA ACEVEDO, ) Index No. _____________ individually and as parent and next friend ) of A.A., a minor child; and ) ) THE KING’S CHOICE LEAH, ) Plaintiffs, ) ) vs. ) COMPLAINT AND ) DEMAND FOR NEW YORK CITY DEPARTMENT OF ) JURY TRIAL EDUCATION; ) ) WILLIAM HARRINGTON, ) in his official capacity as ) Director of the New York City ) Central Office of Home Schooling; ) ) CARMEN FARINA, ) in her official capacity as ) Schools Chancellor of New York City; and ) ) ELIZABETH ROSE, ) in her official capacity as Deputy Schools ) Chancellor for Operations, New York City, ) ) Defendants. ) __________________________________________) Plaintiffs Tanya Acevedo, and The King’s Choice LEAH, by and through counsel, allege upon information and belief the following against Defendants. INTRODUCTION The New York City Department of Education (also known as the “New York City Board of Education” or the “New York City Panel for Education Policy”) oversees the operation of New York City’s thirty-four (34) school districts, as well as the New York City Central Office of Homeschooling. The Department is managed by Defendant Carmen Farina, in her official