Treatment Abuse, Behavior Modification, Thought Reform > Facility Question and Answers
Hyde
Ursus:
Transcription of the ISACCorp document (original on 4 separate pages) on the Dubinsky case. Please see my previous post for the links to jpg scans of the actual documents.
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
XXXX XXXX VS. HYDE SCHOOL AT WOODSTOCK
CIVIL ACTION NO.
MARCH 5, 2002
C O M P L A I N T
1. This is an action by a female student against a private school which, upon information and belief, is the recipient of federal funds, for tolerating and encouraging a pattern of sexual misconduct directed against her and other female students by a male faulty member, over a long period of time.
2. Jurisdiction of this court is invoked under the provisions of Sections 1331, 1343(3) and 1367(a) of Title 28 of the United States Code and this court's supplementary and diversity jurisdiction over the plaintiff's causes of action under state law.
3. The plaintiff is an adult female citizen of the State of XXXXX. She was born on XXX and at all times mentioned herein was an out-of-state student at the defendant's school in Woodstock, Connecticut.
4. The defendant is a private school located in Woodstock, Connecticut. Upon information and belief, the defendant receives federal financial assistance for the operation of its educational and related programs.
5. The amount at issue in this case is greater than seventy-five thousand dollars, exclusive of interest and costs.
6. In 2001, and for several years prior thereto, the defendant employed at its school in Woodstock an adult male teacher by the name of Larry Dubinsky. At all times mentioned herein, said Dubinsky was acting as the agent, servant, and employee of the defendant, within the scope of his employment and agency, and for the defendant's financial benefit.
7. For several years prior to and including the events described hereinafter, the defendant, through its administrators and officials, had actual knowledge that Dubinsky was subjecting the female students at Hyde School to sexual harassment which included inappropriate touching, staring, and comments. Despite such actual knowledge, the defendant retained Dubinsky on its faculty and permitted him to continue to have daily, direct and unsupervised contact with the adolescent female students at the school, including the plaintiff.
8. During the second week of July, 2001, at the school, Dubinsky initiated a "role-playing" incident with the plaintiff in the course of which he insisted upon having full body contact with the plaintiff, repeatedly and over her objection, while making lewd and inappropriate comments to her which included the phrase "fucking pussy".
9. On August 1, 2001, while instructing a dance routine in which the plaintiff was involved, Dubinsky required the plaintiff to be his partner and to dance with him. He required her to bend down in front of him, then lifted her, raised her blouse, felt around her body for her hips and placed his hands on her hips. When the plaintiff objected and moved away from him, he attempted to coerce her into continuing.
10. When the plaintiff complained to the defendants administrators about the aforesaid misconduct, she was summoned to a meeting at which she was required to meet with Dubinsky and was criticized by administrators for not wanting to look at Dubinsky during the meeting. The following day, she was summoned to yet another meeting with administrators, which the administrators concealed from her parents. When school officials were informed in September of 2001 that the plaintiff was suffering from recurring nightmares regarding Dubinsky, a faculty member falsely accused the plaintiff of flirting with another male teacher. Her mother's pleas to the defendant's highest administrators that Dubinsky be kept away from the plaintiff and not allowed on school grounds were rejected. In February of 2002, the plaintiff was required to serve as a waitress at a party given the defendant's headmaster at which other under-age students were required to serve alcoholic beverages. Dubinsky was an invited guest at that party.
11. In the manner described above, the defendant has, on the basis of the plaintiff's sex, excluded her from participation in, denied her the benefits of, and/or subjected her to discrimination under an education program or activity receiving Federal financial assistance in violation of Title IX of the Educational Amendments of 1972, Sections 1681 - 1688 of Title 20 of the United States Code.
12. In the manner described above, the defendant through its aforesaid agent subjected the plaintiff to assault and battery on each of the two separate occasions described above, in violation of Connecticut state law.
13. The conduct of the defendant and its agent described above was extreme and outrageous and was carried out with the knowledge that it probably would cause the plaintiff to suffer emotional distress.
14. In the manner described above, the defendant further acted in negligent disregard of the probability that its conduct would cause the plaintiff, like any person of ordinary sensibilities similarly situated, to suffer emotional distress so severe that physical illness could result.
15. As a direct and proximate result of the acts and omissions of the defendant described above, the plaintiff has suffered severe emotional distress.
WHEREFORE, the plaintiff claims judgment against the defendant for compensatory damages, punitive damages, attorney fees and costs.
CLAIM FOR JURY TRIAL
The plaintiff claims trial by jury.
THE PLAINTIFF
BY:______________
JOHN R. WILLIAMS
Federal Bar No. ct00215
Williams and Pattis, LLC
51 Elm Street
New Haven, CT 06510
TELEPHONE: 203.562.9931
FAX: 203.776.9494
E-MAIL: jrw@johnrwilliams.com
Her Attorney
Anonymous:
This makes me a bit ill thinking about all that must have gone on that didn't even make it to the official complaint. The pain of having to deal with a punitive and hostile administration, not to metnion the false innuendo used to possibly discredit this poor girl's pov when keeping it under wraps was no longer a possibility, reminds me so much of the hyde I once knew.
I guess not much has changed.
Ursus:
Despite everything that transpired, despite the lawsuit even, Hyde continued to keep Dubinsky on campus. I believe that he lost his teaching benefits, but the rationalization for keeping him there was alleged to reside in the fact that his wife still taught there, and that they had kids which were still attending at the time.
Not sure how the needs or safety of the other female students attending at the time were factored into that, but I think it does say something about where Hyde places their priorities and exactly what kind of values they actually do hold dearest.
Anonymous:
It definitely shows a clear lack of regard for the safety of the students by keeping the man on the campus.
He should have been removed and kept away dependent upon the outcome of the court's decision.
Ursus:
The family chose to settle out of court, probably out of consideration for the daughter, and for what she undoubtedly would be put through during the trial. They were assured that "Hyde had learned its lesson."
I think each time such a circumstance arises, the family and the courts are given the impression that these are highly unusual circumstances, and that such a situation could never arise again. Families, or specific members of families, are often portrayed as crazy, having irrational vendettas, or in need of psychological help. The existence of former lawsuits is always downplayed or denied. In Connecticut, the obfuscation was enhanced by the relatively recent establishment of Hyde's Woodstock campus. Information or awareness of cases involving the Bath campus were less accessible.
In truth, such situations have been arising since at least the mid 1970s.
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