Revised Complaint

On August 18, 2014 the firm of Harder, Mirell & Abrams, new attorneys for Anne Josephson, and the two minor children (Child 1 and Child 2), and Michael Josephson, acting in pro per lodged an amended complaint which dropped Archer as a party and added new allegations against the members of the Board of Trustees and Elizabeth English. The new Complaint strengthens allegations against the board for dereliction of duty due to the failure of individuals to meet the standard of care required by state law to provide oversight. The allegations include more specific allegations about past conduct of Elizabeth English that the board either knew about or should have known. Plaintiff’s allege that these incidents put the board on notice of a pattern of abuse of discretion that required them to provide internal controls and guidelines. Defendant’s opposed the filing of the new complaint. We hope you will read the entire complaint to get a coherent story of why this action was brought.

1st Amended Complaint filed 081814

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