Oren Ungerleider Complaint

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------X OREN UNGERLEIDER,

Plaintiff,

-against- COMPLAINT CONTINUUM HEALTH PARTNERS, INC., DR. CLEMENS HEIDERHOFF, DR. KARIN DORELL, DR. TARA MALEKSHAHI, DR. HOWARD MILLMAN, COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK, STEPHANIE NIXON, HAZEL MAY, and New York City police officers JOHN DOES #1-3, each in their individual capacity, Defendants. Demand for Jury Trial ---------------------------------------------------------------X Plaintiff Oren Ungerleider, by and through his attorneys LeBow & Associates, PLLC,

complains of the Defendants, and each of them, as follows:

I. PRELIMINARY STATEMENT

Plaintiff Oren Ungerleider brings this action under 42 USC §§1983 and 1988 to redress

Defendants’ violations of the rights and immunities secured to Plaintiff by the United States

Constitution. Plaintiff was a student at Columbia University who cursed at his Spanish teacher

after he felt he was graded unfairly. After that incident, Columbia official Nixon called the

NYPD, possibly under May’s direction, and officers Does #1-3 arrested Plaintiff based on

Nixon’s statements, and took Plaintiff to the mental health ward at St. Luke’s Hospital to be

involuntarily committed. At St. Luke’s Hospital, doctors Heiderhoff, Dorell, Malekshahi, and

Millman all certified the continuation of Plaintiff’s involuntary commitment despite the fact that

they knew or should have known that he was not dangerous to himself or others. Plaintiff was

Case 1:13-cv-00410-LTS Document 1 Filed 01/17/13 of 17

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eventually held at St. Luke’s for 30 days, which caused him severe emotional distress, and great

disruption in his education and his life. While at St. Luke’s, Plaintiff was given medications

against his will. Plaintiff asserts claims against Continuum Health Partners, Inc. (which operates

St. Luke’s, hereinafter “Continuum”), Heiderhoff, Dorell, Malekshahi, and Millman for false

imprisonment and involuntary medication, and against Columbia, Nixon, May, and Does #1-3

for false arrest and false imprisonment. Plaintiff seeks compensatory and punitive damages from

all Defendants.

II. JURISDICTION AND VENUE

1. This Court has federal question jurisdiction over the federal civil rights claims asserted

herein against Defendants Continuum, Heiderhoff, Dorell, Malekshahi, Millman, Columbia,

Nixon, May, and Does #1-3 pursuant to 28 U.S.C. §§1331 and 1343(a)(3). Venue in this district

is proper because a substantial part of the events giving rise to the claims described herein

occurred in the Southern District of New York.

III. PARTIES

2. At all times relevant herein, Plaintiff Oren Ungerleider was a student at Columbia

University, residing at the Columbia dormitory at 411 West 116th Street, New York, New York

10025, and a citizen of the United States.

3. At all times relevant herein, Defendant Columbia University in the City of New York

(“Columbia”) was a private university at the address 2960 Broadway, New York, New York

10027. Plaintiff attended Columbia at the time of the events herein, and Columbia employed

Defendants Nixon and May.


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4. At all times relevant herein, Defendant Continuum Health Partners, Inc.

(“Continuum”) was a non-profit hospital system that operates medical facilities including St.

Luke’s Hospital (“St. Luke’s”) at 1111 Amsterdam Avenue, New York, New York 10027, which

operates the mental health ward in which Plaintiff was involuntarily committed.

5. At all times relevant herein, Defendant Dr. Clemens Heiderhoff was a medical doctor

employed by St. Luke’s to examine, treat and care for patients diagnosed with a mental disorder,

disease or illness, and specifically examines whether a patient may be involuntarily committed as

a danger to himself or others. Dr. Heiderhoff personally examined Plaintiff, and made specific

findings leading to Plaintiff's unlawful confinement, all while acting under the color of state law.

6. At all times relevant herein, Defendant Dr. Karin Dorell was a medical doctor



a danger to himself or others. Dr. Dorell personally examined Plaintiff, and made specific


7. At all times relevant herein, Defendant Dr. Tara Malekshahi was a medical doctor



a danger to himself or others. Dr. Malekshahi personally examined Plaintiff, and made specific


8. At all times relevant herein, Defendant Dr. Howard Millman was a medical doctor and

the unit chief at St. Luke’s’ adult inpatient psychiatry unit (mental health ward), in which

Plaintiff was committed. On information and belief, Dr. Millman is the policy-maker for St.

Luke’s mental health ward regarding all aspects of patient care, treatment, and involuntary


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commitment, and he also has supervisory responsibility for the treatment and care provided by

the staff, with attendant responsibility for the training, discipline, and retention of staff.

Defendant Millman also personally evaluated and examined Plaintiff herein, and made specific


9. At all times relevant herein, Defendants Does #1-3 were NYPD officers, likely from

the 26th Precinct in Harlem, which has jurisdiction over Columbia and St. Luke’s.

10. At all times relevant herein, Defendant Hazel May was a Columbia assistant to the

Dean, and had supervisory authority over Nixon.

11. At all times relevant herein, Defendant Stephanie Nixon was Columbia’s Director of

Residential Programs.

IV. STATEMENT OF FACTS

12. At all times relevant herein, Plaintiff Oren Ungerleider was a student at Columbia

University. Plaintiff had no history of being cited for any mental health issues in the past. Prior

to the events herein, Plaintiff was an accomplished classical violinist who had performed with

professional orchestras, had won competitions, and had toured internationally.

13. At all times relevant herein, Defendant Columbia was a private university that

Plaintiff attended and that employed Nixon and May.

14. At all times relevant herein, Defendant Continuum was a non-profit hospital system

that operates medical facilities including St. Luke’s.

15. At all times relevant herein, Defendant Dr. Clemens Heiderhoff was a doctor in St.

Luke’s mental health unit.


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16. At all times relevant herein, Defendant Dr. Karin Dorell was a doctor in St. Luke’s

mental health unit.

17. At all times relevant herein, Defendant Dr. Tara Malekshahi was a doctor in St.

Luke’s mental health unit.

18. At all times relevant herein, Defendant Dr. Howard Millman was a doctor in St.

Luke’s mental health unit, and the unit chief of the mental health unit, with supervisory authority

over Heiderhoff, Dorell, and Malekshahi.

19. At all times relevant herein, Defendant Does #1-3 were NYPD officers.

20. At all times relevant herein, Defendant Hazel May was a Columbia assistant to the

Dean, with supervisory authority over Nixon.

21. At all times relevant herein, Defendant Stephanie Nixon was Columbia’s Director of

Residential Programs.

22. On or about December 20, 2010, at around 3:00 PM, Plaintiff went to his final exam

in Spanish. Before the final exam started, the teacher was handing out grades for the final

project that was done by pairs of students the week before. The teacher gave Plaintiff’s final

project partner a note with the grade 80/100, and gave Plaintiff a note stating “Your Spanish is

horrible. You didn’t say one word correctly. 50/100, F.”

23. On information and belief, Plaintiff handed the teacher back the note, called her a

bitch, sat down, waited five minutes, and when the teacher handed him a copy of the final exam,

he handed it right back and left the room, while telling the class he was sorry for the disruption.

24. On or about December 21, 2010, Plaintiff emailed Hazel May, a Columbia assistant

to the Dean, saying that he admitted to using bad language in a Spanish class, was sorry for it,

and thought that the teacher was grading him unfairly.


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25. On or about December 21, 2010, at around 2:00 PM, Plaintiff met with Ms. May, and

again said that he apologized for using bad language in a Spanish class. Plaintiff showed Ms.

May his final project and the note he received from the teacher as evidence that his grade was

unfairly low. Ms. May told Plaintiff that she wanted him to see a psychiatrist.

26. On information and belief, Ms. May directed Stephanie Nixon, Columbia’s Director

of Residential Programs, to go to Plaintiff’s room that night.

27. On or about December 22, 2010, at around 12:30 AM, Ms. Nixon knocked on

Plaintiff’s dorm room’s door. Plaintiff did not answer. The door then became unlocked, and

Plaintiff walked over to shut it. Next, three Columbia security officers entered the room.

28. On information and belief, Ms. Nixon handed Plaintiff an official letter with a

Columbia header stating that he had a judicial hearing in response to profanity used in a Spanish

class. Ms. Nixon told Plaintiff that she wanted him to see a campus psychiatrist. Plaintiff asked

her who she was, why she was in his room at 12:30 AM, and why she had any right to be in his

room when there were no allegations of guns, drugs, or violence, and no warrant.

29. On information and belief, Ms. Nixon then stepped out of Plaintiff’s dorm room to

call the NYPD, and told the three Columbia security officers to keep Plaintiff in the room.

NYPD officers Does #1-3 arrived at Plaintiff’s dorm room, handcuffed him, escorted him into an

ambulance, and drove him to St. Luke's. Does #1-3 did not conduct any investigation, and did

not ask Plaintiff for his side of the story, and only one officer even said anything to him, and that

was only to tell him that they were bringing him to the hospital.

30. On or about December 22, 2010, at around 1:00 AM, Plaintiff was brought to a room

at St. Luke’s. A psychiatrist entered the room and interviewed Plaintiff, and after that

psychiatrist left, another psychiatrist entered the room and interviewed Plaintiff. The


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psychiatrists asked Plaintiff whether he took marijuana or other drugs that day. Plaintiff was

insulted by their questions, found them rude, and refused to even respond. One of the

psychiatrists told Plaintiff that he wanted him to stay the night at the hospital. Plaintiff said no,

and started to walk out of the room.

31. On information and belief, three doctors came over, tackled Plaintiff, and forcefully

injected him with a liquid containing the drug Haldol. Plaintiff repeatedly asked them, "what are

you sticking in my body?", but they did not respond. The substance sedated Plaintiff and he

could barely walk. He was then asked to urinate in a cup to check for drugs in his system.

Shortly thereafter, he fell asleep from the sedation, and has no further memories from that night.

32. On or about December 22, 2010, at around 6:30 AM, Plaintiff awoke and was

examined by Dr. Clemens Heiderhoff, who signed a certification for Plaintiff’s involuntary

commitment.

33. On or about December 22, 2010, at around 8:00 AM, Plaintiff was examined by Dr.

Karin Dorell, who signed a certification for Plaintiff’s involuntary commitment, and noted that

Plaintiff had no previous psychiatric history.

34. On or about December 22, 2010, at or around 8:30 AM, Plaintiff asked to be allowed

to leave, but was not allowed to leave.

35. On or about December 22, 2010, at or around 3:15 PM, Plaintiff’s brother Tavi came

to visit him. Tavi asked to remove Plaintiff from the hospital, but the staff refused to release

him.

36. On or about December 23, 2010, Plaintiff met with Dr. Tara Malekshahi, who

described him as “cooperative, pleasant, and calm”, but stated that he had “grandiose and

paranoid delusions” and an illogical and at times incoherent thought process, and called for


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holding Plaintiff based on Dr. Heiderhoff and Dr. Dorell’s certifications, and giving Plaintiff

anti-psychotic medication. Dr. Malekshahi also noted that Plaintiff had no previous

psychological history. St. Luke’s unit chief Dr. Howard Millman signed Dr. Malekshahi’s

report.

37. From December 23, 2010 through January 21, 2011, Dr. Millman examined Plaintiff

numerous times, and supported Plaintiff’s continued commitment.

38. On or about January 4, 2011, Plaintiff made a request for a court hearing to challenge

his continued hospitalization.

39. On or about January 6, 2011, Plaintiff was taken to court. Dr. Millman stated that

there was a possibility of schizophrenia, but he did not state that there was an actual diagnosis of

schizophrenia. Dr. Millman started talking about how Plaintiff’s grades at Columbia dropped,

how Plaintiff didn't practice much violin anymore, how Plaintiff didn't talk to his parents every

day, and specifically that Plaintiff didn't want to see his parents while in the mental ward.

Plaintiff was only able to talk for about ten seconds before being cut off, and was only

able to say that “everything Mr. Millman said was wrong”, and to disagree with some specific

points, stating that the decline in his grades does not show that he was a risk to harm himself or

anyone else, and that he did not commit physical violence against any teachers. The court ruled

that St. Luke’s could continue to hold Plaintiff.

40. During the time of Plaintiff’s commitment in St. Luke’s, he was placed in dangerous

and traumatizing situations, including being in the constant presence of dangerous mentally ill

individuals, being put in therapy groups with the severely mentally ill, and being forcibly

medicated.

41. On or about January 21, 2011, Plaintiff was released from St. Luke’s.


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42. After January 21, 2011, Plaintiff was not able to return to Columbia, and had to take a

year and a half away from continuing his university studies before enrolling in the Ohio State

University for the fall term of 2012-3.

43. After January 21, 2011, Plaintiff lost any desire to play the violin, which had been an

important part of his life.

44. After January 21, 2011, Plaintiff suffered emotional distress from his confinement at

St. Luke’s, and frequently has recurring thoughts about the trauma he experienced there.

V. FIRST CAUSE OF ACTION - CIVIL RIGHTS AND CONSTITUTIONAL VIOLATIONS

False Imprisonment (Against Defendants Continuum, Heiderhoff, Dorell, Malekshahi, and Millman)

45. Plaintiff repeats, reiterates, and realleges each and every allegation contained in

paragraphs 1 through 44 of this Complaint with the same force and effect as though fully set

forth herein.

46. As a result of the actions of Defendants Heiderhoff, Dorell, Malekshahi, and

Millman, which began on or about December 22, 2010, Plaintiff was deprived of his rights under

the United States Constitution and federal civil rights law. Plaintiff’s rights are secured by

provisions of the Fourth Amendment and 42 U.S.C. §1983.

47. The actions of Defendants Heiderhoff, Dorell, Malekshahi, and Millman were

committed under the color of law, since (1) they committed Plaintiff to St. Luke’s under

instruction from NYPD officers, (2) they were performing the public function of involuntary

commitment, and (3) from January 6, 2011 through January 21, 2011, they continued to confine

Plaintiff pursuant to a court order.


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48. The actions of Defendants Heiderhoff, Dorell, Malekshahi, and Millman were

intentional and willful.

49. On and after December 22, 2010, Defendants Heiderhoff, Dorell, Malekshahi, and

Millman intended to confine Plaintiff.

50. On and after December 22, 2010, Plaintiff was conscious of being confined.

51. On and after December 22, 2010, Plaintiff at no time consented to being confined by

Defendants Heiderhoff, Dorell, Malekshahi, and Millman. From the very beginning of his

involuntary commitment on December 22, 2010, Plaintiff voiced his objection to his involuntary

commitment at St. Luke’s, and continued to do so throughout his involuntary commitment, and

Defendants Heiderhoff, Dorell, Malekshahi, and Millman were aware of Plaintiff’s objections.

52. On or about December 22, 2010, Heiderhoff, Dorell, Malekshahi, and Millman knew

the following information about Plaintiff, in addition to their examinations of him: (1) he had

cursed at his Spanish teacher, (2) he refused to open the door to Ms. Nixon, a Columbia

residential official, and (3) he had no previous history of mental health issues.

53. On or about December 22, 2010, Heiderhoff and Dorell signed certifications that

stated that (1) Plaintiff was in need of involuntary care and treatment, because he had a mental

illness for which care and treatment in a mental hospital was essential for his welfare, and his

judgment was so impaired that he was unable to understand the need for such treatment, and (2)

as a result of his mental illness, he posed a substantial risk of harm to himself or others, because

of his inability to meet his own needs or a history of dangerous conduct.

54. On or about December 23, 2010, Malekshahi called for holding Plaintiff involuntarily

based on her own examination and Heiderhoff and Dorell’s certifications.


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55. On or about December 23, 2010, Millman approved Malekshahi’s call to hold

Plaintiff involuntarily.

56. From December 23, 2010 through January 21, 2011, Millman examined Plaintiff

several times, and called for continuing to hold Plaintiff involuntarily.

57. Plaintiff was held at St. Luke’s against his will until January 21, 2011.

58. Reasonable doctors in the position of Heiderhoff, Dorell, Malekshahi, and Millman

could not have reasonably believed that Plaintiff posed a substantial risk of harm to himself or

others based on their examinations of Plaintiff and the other information available to them, and

therefore they did not have probable cause to call for Plaintiff’s involuntary commitment.

59. For Heiderhoff, Dorell, Malekshahi, and Millman to conclude that Plaintiff posed a

substantial risk of harm to himself or others based on their examinations of Plaintiff and the other

information available to them was a significant deviation from generally accepted medical

standards.

60. For Heiderhoff, Dorell, Malekshahi, and Millman to cause Plaintiff to be committed

involuntarily when they could not have reasonably believed that Plaintiff posed a substantial risk

of harm to himself or others based on their examinations of Plaintiff and the other information

available to them was a violation of Plaintiff’s Fourth Amendment rights.

61. In view of the fact that Heiderhoff, Dorell, Malekshahi, and Millman intended to

confine Plaintiff, Plaintiff was conscious of his confinement, Plaintiff did not consent to his

confinement, and the confinement was not privileged since they did not have probable cause to

involuntarily commit Plaintiff, Plaintiff’s confinement was therefore unlawful and actionable

under 42 U.S.C. §1983.


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62. The actions of Heiderhoff, Dorell, Malekshahi, and Millman amounted to false

imprisonment under 42 U.S.C. §1983 and the Fourth Amendment of the United States

Constitution.

63. Managerial personnel at St. Luke’s, including Millman, created the policy and custom

under which St. Luke’s doctors would certify Plaintiff and individuals like him for involuntary

commitment despite the fact that they could not reasonably be thought of by competent

psychiatric personnel as being dangerous to themselves or others, and doing so without probable

cause, in violation of those individuals’ constitutional rights. That policy and custom was the

proximate cause of Plaintiff’s involuntary commitment and false imprisonment, and Continuum

as the owner and operator of St. Luke’s is therefore responsible for the violation of Plaintiff’s

constitutional rights.

64. As a direct and proximate result of Plaintiff’s false imprisonment, Plaintiff was

caused to suffer confinement in a mental health ward for 30 days, a loss of freedom and liberty,

great mental anguish, emotional distress, public humiliation, and dangerous conditions during the

time of his confinement, the disruption of his education and social life, lost future income and

opportunities due to having to leave Columbia University, the end of his musical activities and

passion for the violin, and continuing emotional distress as a result of his confinement.

VI. SECOND CAUSE OF ACTION - CIVIL RIGHTS AND CONSTITUTIONAL VIOLATIONS

Involuntary Medication (Against Defendants Continuum, Heiderhoff, Dorell, Malekshahi, and Millman)


paragraphs 1 through 64 of this Complaint with the same force and effect as though fully set forth

herein.


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66. From December 22, 2010 through January 21, 2011, Heiderhoff, Dorell, Malekshahi,

and Millman caused Plaintiff to be medicated against his will, and without probable cause to

believe that he was a danger to himself or others, and thereby violated his rights under 42 U.S.C.

§1983 and the Fourth and Fourteenth Amendments of the United States Constitution.

67. Managerial personnel at St. Luke’s, including Millman, created the policy and custom

under which St. Luke’s doctors would medicate Plaintiff and individuals like him against their

will despite the fact that they could not reasonably be thought of by competent psychiatric

personnel as being dangerous to themselves or others, and doing so without probable cause, in

violation of those individuals’ constitutional rights. That policy and custom was the proximate

cause of Plaintiff being subjected to medication against his will, and Continuum as the owner

and operator of St. Luke’s is therefore responsible for the violation of Plaintiff’s constitutional

rights.

68. As a direct and proximate result of Heiderhoff, Dorell, Malekshahi, and Millman’s

forcing medications on Plaintiff against his will, and without probable cause to believe that he

was a danger to himself or others, Plaintiff experienced a violation of his personal liberty and of

the dignity of his body, experienced emotional distress, and may suffer physical and mental

health effects from the medications he was given.

VII. THIRD CAUSE OF ACTION - CIVIL RIGHTS AND CONSTITUTIONAL VIOLATIONS

False Arrest and False Imprisonment (Against Defendants Columbia, May, Nixon, and Does #1-3)


paragraphs 1 through 68 of this Complaint with the same force and effect as though fully set forth

herein.


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70. As a result of the actions of Defendants May, Nixon, and Does, which began on or

about December 22, 2010, Plaintiff was deprived of his rights under the United States

Constitution and federal civil rights law. Plaintiff’s rights are secured by provisions of the

Fourth Amendment and 42 U.S.C. §1983.

71. The actions of Defendants May, Nixon, and Does were committed under the color of

law and were intentional and willful.

72. On or about December 22, 2010, Defendants May and Nixon intended to have

Plaintiff arrested and confined in a mental hospital, and Defendants Does intended to arrest

Plaintiff and confine Plaintiff in a mental hospital.

73. On or about December 22, 2010, Plaintiff was conscious of being arrested and

confined in a mental hospital.

74. On or about December 22, 2010, Plaintiff at no time consented to being arrested and

confined by Defendants Does, but nonetheless cooperated with them because they were NYPD

officers acting in an official capacity.

75. On or about December 22, 2010, Nixon, acting under May’s direction, gave

information to Does that resulted in Plaintiff’s arrest and confinement in St. Luke’s.

76. On information and belief, it is not clear what Nixon told Does. If Nixon told Does

the truth – that the only actions Plaintiff had committed were (1) one curse word directed at a

teacher who he felt had treated him unfairly, (2) his refusal to open his door at 12:30 AM, and

(3) his objection to Nixon and the security officers entering his room without suspicion of

criminal activity or a warrant, then Does would have had no probable cause to arrest Plaintiff and

take him to St. Luke’s for confinement. If instead, Nixon falsified or exaggerated Plaintiff’s

actions to Does in order to have Plaintiff arrested and taken to St. Luke for confinement, then


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Nixon and May would be responsible for having Plaintiff arrested and taken to a mental health

ward based on false or incomplete information.

77. On or about December 22, 2010, any reasonable officer in Does’ position would have

allowed Plaintiff to tell his side of the story, or at least conversed with him, before concluding

that he was mentally ill and a danger to himself or others, and before arresting him for

confinement in a mental hospital, and Does failed to do so.

78. On or about December 22, 2010, if the information from Nixon was truthful, any

reasonable officer in Does’ position would have seen that the information from Nixon about

Plaintiff’s actions was insufficient to establish the belief that he was mentally ill and a danger to

himself or others, and would not have arrested him for confinement in a mental hospital.

79. On or about December 22, 2010, based on the facts and circumstances known to Does

at the time they seized Plaintiff, they did not have sufficient information about Plaintiff that

would warrant a person of reasonable caution to believe that he might be mentally ill and

conducting himself in a manner likely to result in serious harm to himself or others.

80. In view of the fact that Does did not have sufficient information about Plaintiff that

would warrant a person of reasonable caution to believe that he might be mentally ill and

conducting himself in a manner likely to result in serious harm to himself or others, they did not

have probable cause to arrest Plaintiff, and take Plaintiff to St. Luke’s to be confined there.

81. That neither on nor about December 22, 2010, nor at any other relevant time herein,

did such a warrant for Plaintiff’s arrest and confinement exist, and a court order for Plaintiff’s

confinement did not exist at the time he was initially taken to St. Luke’s by Does.

82. In view of the fact that Defendants Nixon and May intended to have Plaintiff arrested

and confined in a mental hospital, Does intended to arrest and confine Plaintiff in a mental


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hospital, Plaintiff was conscious of his confinement and did not consent to it, and the

confinement was not privileged since it was not conducted pursuant to a warrant or probable

cause, Plaintiff’s confinement was therefore unlawful and actionable under 42 U.S.C. §1983.

83. The actions of Defendants Nixon, May, and Does amounted to false arrest and false

imprisonment under 42 U.S.C. §1983 and the Fourth Amendment of the United States

Constitution.

84. Managerial personnel at Columbia created the policy and custom under which

Columbia personnel would arrange for Plaintiff and individuals like him to be arrested and

involuntarily committed despite the fact that they could not reasonably be thought of by

competent psychiatric personnel as being dangerous to themselves or others, and doing so

without probable cause, in violation of those individuals’ constitutional rights. That policy and

custom was the proximate cause of Plaintiff being involuntarily committed, and Columbia is

responsible for the violation of Plaintiff’s constitutional rights.

85. As a direct and proximate result of Plaintiff’s false arrest and false imprisonment,

Plaintiff was caused to suffer confinement in a mental health ward for 30 days, a loss of freedom

and liberty, great mental anguish, emotional distress, public humiliation, and dangerous

conditions during the time of his confinement, the disruption of his education and social life, lost

future income and opportunities due to having to leave Columbia University, the end of his

musical activities and passion for the violin, and continuing emotional distress as a result of his

confinement.

WHEREFORE Plaintiff demands judgment against each of Continuum, Heiderhoff,

Dorell, Malekshahi, Millman, Columbia, Nixon, May, and Does #1-3 in the amount of Five


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Million Dollars ($5,000,000.00) in compensatory damages and Five Million Dollars

($5,000,000.00) in punitive damages on the first, second, and third causes of action, together

with attorneys’ fees, and the costs and disbursements associated with bringing this action.

Dated: New York, New York Respectfully submitted, January 17, 2013 LEBOW & ASSOCIATES, PLLC

_______________________

James B. LeBow, Esq. (JL4535) 570 Lexington Avenue, 16th Floor New York, New York 10022 Tel. (212) 868-3311 Fax (646) 619-4555


Oren Ungerleider Complaint

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