From 1st Amended Complaint
34. English’s modus operandi of making false and misleading statements to disguise her vindictive actions is demonstrated in her June 24, 2014 declaration filed in this action where she essentially accuses Michael of attempting to intimidate her: “During this time it was my impression that Mr. Josephson attempted to intimidate me and other school administrators so that his daughter could avoid having to appear before the HEC.” Given Michael’s status as a well-known ethicist this is a very serious charge. English seeks to hide her own bullying by calling her victim a bully. There was no intimidation.
English had all the leverage and she knew it. She held the Josephson children hostage to her whims and her unremitting efforts to humiliate Michael and to bully the Josephson family to passively accept an improper and unprofessional decision that would, and was calculated to, cause great injury.
Every single interaction between Michael and English is either in writing or tape-recorded and there is not a single word or action that English has pointed to justify her statement that she “felt” intimidated. This is a fiction designed to assassinate the reputation of Michael. On information and belief, English has used this same intimidation claim against other parents who were doing no more than advocating for their children.
The “I feel intimidated” ploy arose again in another part of English’s deposition:
12. I believe that events that took place six years ago also motivated Mr. Josephson to file this lawsuit. In 2009, during my first year at Archer, the school was in the process of establishing an Honor Code and Honor Education Council, a model which has been used by independent schools throughout the country. The Josephsons approached me with an offer to use their Institute’s Character counts survey as an educational tool free of charge. I accepted the offer. However I also indicated to Mr. Josephson that the school was working with another professional organization in the establishment of our Honor Code. When I declined Mr. Josephson’s repeated attempts to have the School further use and support his company, the Josephson institute and its Character Counts curriculum, I felt intimidated by his reaction, so much so that I enlisted the help of the Board of trustees in responding to him
This is another gross distortion of the facts and another invocation of her vague feeling of being intimidated. (We have learned she has used that same ploy with other parents to justify clearly improper actions).
Similarly, there is not a shred of evidence, and Mr. Josephson unequivocally denies that he did anything that could remotely be characterized as intimidating. If he said or did anything that could be reasonably construed as intimidating, it was incumbent on Ms. English to specify those fact in her declaration. She didn’t because this is a pretext, another cover-up for the next distortion. The declaration creates a clever distraction as the reference to enlisting members of the board of trustees “in responding to” Mr. Josephson is completely out of context.
There is also not a shred of evidence, and Mr. Josephson unequivocally denies that he made repeated efforts “to have the School further use and support his company.” This is preposterous on its face. The Josephson institute of Ethics is a nonprofit organization, Mr. Josephson performed as CEO as a full-time volunteer, receiving no compensation and everything offered to Archer was at no cost. Mr. Josephson had no objection to Ms. English’s decision to develop her own character development program.