From the Original Complaint Paragraph 1
Plaintiffs MICHAEL JOSEPHSON (“MJ”) and ANNE JOSEPHSON (“AJ”) are, and all times relevant hereto were, individuals residing in Los Angeles County. Since 2005, MJ and AJ were widely considered by teachers, staff, administrators and parents at THE ARCHER SCHOOL FOR GIRLS (“ARCHER”) to be exemplary, active, and positive members of the ARCHER community having enrolled all four of their daughters at ARCHER; each daughter has been a positive asset to the school. At all times relevant to these allegations, MJ and AJ were capable of and committed to continuing their positive relationship ARCHER.
- a) S. Josephson, AJ and MJ’s eldest daughter graduated in 2011, having distinguished herself academically and in ARCHER’s theater program.
- b) A. Josephson, AJ and MJ’s second daughter, is the only ARCHER student ever to be selected by the faculty to deliver the valedictory addresses at both her middle school and high school commencement ceremonies. She graduated in 2013 after receiving school and national awards for her performances in ARCHER’s theater program.
- c) Plaintiff C. JOSEPHSON (“CHILD 1”), the third daughter of MJ and AJ, is a resident of Los Angeles County. She attended ARCHER since the sixth grade, was widely respected by faculty and classmates (she was selected by peers and faculty for leadership in the school’s dance program), and was very active in global social causes (including spending one summer in Ghana and another in Cambodia volunteering to assist orphan children). CHILD 1’s application to Barnard College for early decision was supported by strong letters from teachers and administrators at ARCHER. In December 2013 she was admitted subject to completion of her senior year. CHILD 1 was in her last semester at ARCHER when she was wrongfully forced to leave the school.
- d) Plaintiff M. JOSEPHSON (“CHILD 2”), the youngest daughter of MJ and AJ, is a resident of Los Angeles County. She attended ARCHER since the 6th grade and was in the midst of her 10th grade year when, in retaliation for MJ’s efforts to advocate on behalf of CHILD 1, she was wrongfully forced to leave the school. CHILD 2 was a very popular and well-respected student with exceptional singing and acting talent (she was selected for lead roles in ARCHER theater productions almost every year she has been at the school) and she participated in ARCHER’s sports program.
- e) ANNE JOSEPHSON is a successful and well-respected businesswoman who founded the Josephson Academy of Gymnastics. From 2005 until February 2014 she was a highly visible and effective volunteer with extensive and intensive personal relationships with many ARCHER administrators, staff and faculty. AJ was known as one of the school’s best advocates and active recruiters of both faculty and students. In 2012, at the invitation of ARCHER’s Head of School, defendant Elizabeth English she became a member of THE ARCHER BOARD OF TRUSTEES and served on that board with distinction until she was forced to resign.
- f) MICHAEL JOSEPHSON is a nationally known radio commentator, speaker, writer and consultant on ethics and character who served from 1985 – 2013 as CEO of the Joseph & Edna Josephson Institute of Ethics (he retired in January 2014), a nonprofit 501c3 corporation he founded in honor of his parents. 1) The Institute’s CHARACTER COUNTS! and PURSUING VICTORY WITH HONOR programs reach about 8 million students worldwide. MJ was awarded America’s Prize for Integrity by former President Ronald Reagan and maintaining an unsullied reputation for ethics and integrity is crucial to his profession. 2) MJ frequently provided voluntary services to ARCHER including a three day character development workshop for faculty (at the request of ENGLISH’s predecessor); a school-wide survey of ARCHER student attitudes and behavior accompanied by a report and discussion guide to constructively respond to the vulnerabilities revealed by the survey (commissioned by ENGLISH ); and various presentations for ARCHER parents and students.