rosenberg, nathan (assault)

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS

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NATHAN ROSENBERG, a/k/a NUCHUM ROSENBERG,

Plaintiff,

-against-

MEILECH SCHNITZLER,

Defendant.

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Index No: / 15

Date Purchased: 9 / 1 / 15

Plaintiffs designate KINGS County as the

place of trial. The basis of venue is

plaintiff’s residence

SUMMONS

Plaintiff resides at:

131 Division Ave., B’klyn, NY

TO THE ABOVE NAMED DEFENDANTS:

YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your

answer, on the plaintiff’s Attorneys within 20 days after the service of this summons, exclusive of the day of service

(or within 30 days after service is complete if this summons is not personally delivered to you within the State of

New York) and to file a copy of your answer with the Clerk of the above-named Court; and in case of your failure to

appear or answer, judgment will be taken against you by default for the relief demanded in the complaint.

Dated: Brooklyn, New York

September 2, 2015

Yours,

THE BERKMAN LAW OFFICE, LLC

Attorneys for the plaintiff

by:

Robert J. Tolchin

111 Livingston Street, Suite 1928

Brooklyn, New York 11201

(718) 855-3627

Defendant’s address:

SEE ATTACHED RIDER

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RIDER

Defendants’ addresses:

Meilech Schnitzler

156 South 8th Street, Apt. 31C



COUNTY OF KINGS

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NATHAN ROSENBERG, a/k/a NUCHUM

ROSENBERG,

Plaintiff,

-against-

MEILECH SCHNITZLER,

Defendants.

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Index No: ___________ / 15

VERIFIED COMPLAINT

Plaintiff, complaining of the defendants, by his attorneys, THE BERKMAN LAW

OFFICE, LLC, alleges for his complaint, upon information and belief, as follows:

THE PARTIES

1. At all times mentioned herein, the plaintiff, NATHAN ROSENBERG a/k/a

NUCHEM ROSENBERG (“ROSENBERG”), is a natural person who is a resident of the State of

New York, County of Kings.

2. Upon information and belief, at all times relevant to this complaint, the defendant

MEILICH SCHNITZLER (“SCHNITZLER”) is a natural person who is a citizen and resident of

the State of New York, County of Kings.

THE UNDERLYING FACTS

3. The plaintiff is a well-known advocate against child sexual abuse in the insular

Hasidic Orthodox Jewish community of Brooklyn and through this advocacy has brought

information about pedophiles in that community to light.

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4. For the past decade, the plaintiff has maintained a hotline and an internet website

that educate parents in the Orthodox Jewish community regarding sexual misconduct against

children in schools, synagogues and ritual baths (mikvehs).

5. As a result of the plaintiff’s hard work and efforts, victims have started to come

forward, cooperate with law enforcement in prosecuting the abusers, and have also obtained

therapy to help them deal with the aftermath of being abused.

6. Unfortunately, pedophilia is a taboo topic in the Orthodox Jewish community and

has been kept secret, and victims have previously been encouraged not to speak up or cooperate

with law enforcement.

7. As a result of the plaintiff’s efforts, in recent years many victims have come

forward, abusers have been stopped and prosecuted, and justice has been achieved.

8. The defendant SCHNITZLER is apparently a supporter of the pedophiles, or at

least supports protecting pedophiles from being revealed and brought to justice.

9. On or about December 11, 2012, the defendant SCHNITZLER threw bleach in

plaintiff ROSENBERG’s eyes, apparently in retribution for ROSENBERG having revealed

information about pedophiles victimizing the community.

10. The attack was premeditated and deliberate: SCHNITZLER crossed the street

from his store, ran behind the plaintiff, tapped plaintiff on the shoulder, and when plaintiff turned

around threw bleach in plaintiff’s eyes.

11. SCHNITZLER’s attack on ROSENBERG was plainly motivated by retribution

for ROSENBERG’s activities as a public advocate against sexual abuse, as the attack took place

on the day after a jury found Nechemya Weberman guilty on 59 counts of child sexual

misconduct, People v. Weberman, 1589-11 (Sup. Ct. Kings County). Mr. Weberman had an

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ongoing sexual relationship with a minor whom he counseled, and was sentenced to 103 years in

jail.

12. Plaintiff’s hotline extensively discussed the Weberman trial, and many people in

the Orthodox Jewish community were upset by the guilty verdict and by extension upset at the

plaintiff for speaking out against Weberman.

13. Some rabbis in the Orthodox community have spoken out against ROSENBERG

and have branded him an “informer” or “rat” for speaking to law enforcement about sexual

misconduct by other members of the community.

14. SCHNITZLER was arrested and ultimately pleaded guilty to felony assault in the

second degree for this attack.

15. Despite having pleaded guilty to a felony, upon information and belief

SCHNITZLER views himself as a hero, and has surrounded himself with members of the

community who also view him as a hero for attacking ROSENBERG.

16. Upon information and belief, SCHNITZLER viewed himself as an “enforcer”

entitled to take revenge against ROSENBERG for informing or “ratting” other members of the

community.

17. As a result of SCHNITZLER’s attack, the plaintiff was caused to become

seriously and permanently injured.

18. As a result of SCHNITZLER’s attack, the plaintiff was caused to suffer severe

and permanent personal injuries including: injuries to eye; permanent damage to eye; ongoing

constant pain in eye; required to continually use eye drops; plaintiff was required to receive

medical care and attention and upon information and belief will require additional medical care

and attention in the future; plaintiff was required to undergo diagnostic testing including x-ray

and/or MRI and/or CT scan; plaintiff was required to undergo physical therapy and/or will

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require additional therapy in the future; plaintiff has been required to take medication and upon

information and belief may be required to take such medication in the future; plaintiff’s ability to

pursue usual duties and vocation has been impaired; plaintiff has become substantially disabled;

plaintiff has suffered severe mental anguish and distress; osteoarthritic changes are anticipated;

extreme pain and suffering; and plaintiff has been otherwise damaged; upon information and

belief, the cost to the plaintiff of life insurance and/or disability insurance has been substantially

increased; all of these injuries are permanent in nature and continuing into the future.

AS AND FOR A FIRST CLAIM FOR RELIEF

19. Plaintiff repeats and re-alleges each of the foregoing allegations with the same

force and effect as if more fully set forth herein.

20. At all times mentioned herein, plaintiff was caused to suffer severe and permanent

personal injures due to the intentional acts of the defendant, such injuries being set forth in detail

above.

21. As a result of the defendant’s actions, the plaintiff was caused to suffer severe and

permanent personal injuries, such injuries being set forth above in greater detail.

22. The defendant’s actions, being deliberate and intended to seek retribution against

the plaintiff for expressing his views and acting against pedophiles who were victimizing

children, were beyond the limits of human decency, and as a result plaintiff is entitled to recover

punitive and exemplary damages, in addition to his actual damages.

23. By reason of the foregoing, the plaintiff is entitled to recover the full extent of his

actual damages, plus punitive damages, in amounts to be determined by the jury at trial.

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WHEREFORE, the plaintiff demands judgment against the defendants in the

amounts and for the relief requested herein, plus attorney’s fees to the extent permitted

by law.


September 2, 2015

Yours,



by:

Robert J. Tolchin



(718) 855-3627

VERIFICATION

Robert J. Tolchin, an attorney for the plaintiffs in the within action, duly admitted to

practice in the Courts of the State of New York, affirms the following statements to be true under

the penalties of perjury, pursuant to CPLR 2016:

He has read the foregoing complaint and knows the contents thereof to be true to his own

knowledge except as to those matters therein stated to be alleged on information and belief, and

as to those matters he believes it to be true.

He further states that the source of this information and the grounds for her belief are

derived from the file maintained in the normal course of business of the attorneys for the plaintiff

herein.

He further states that the reason this affirmation is not made by the plaintiff is that at the

time the complaint was being prepared, the plaintiff was not found to be within the County of

Kings, which is the county where the attorney for the plaintiff herein maintains his office.


September 2, 2015

Robert J. Tolchin


COUNTY OF KINGS

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ROSENBERG,

Plaintiff,

-against-

MEILECH SCHNITZLER,

Defendants.

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Index No: ___________ / 15

NOTICE OF COMMENCEMENT OF ACTION

SUBJECT TO MANDATORY ELECTRONIC FILING

PLEASE TAKE NOTICE, that the matter captioned above, which has been commenced

by filing of the accompanying documents with the County Clerk, is subject to mandatory

electronic filing pursuant to § 202.5-bb of the Uniform Rules for Trial Courts. This notice is

being served as required by subdivision (b)(3) of that section.

The New York State Court Electronic Filing System (“NYSCEF”) is designed for the

electronic filing of documents with the County Clerk and the Court and for the electronic service

of those documents, court documents, and court notices upon counsel and self-represented

parties. Counsel and/or parties who do not notify the court of claimed exemption (see below) as

required by Section 202.5-bb(e) must immediately record their representation within the e-filed

matter on the Consent page in NYSCEF. Failure to do so may result in an inability to receive

electronic notice of document filings.

Exemptions from mandatory e-filing are limited to: 1) Attorneys who certify in good

faith that they lack the computer equipment and (along with all employees) the requisite

knowledge to comply; and 2) self-represented parties who choose not to participate in e-filing.

For additional information about electronic filing, including access to § 202.5-bb, consult the

NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center at 646-

386-3033 or [email protected].

http://www.nycourts.gov/efile

mailto:[email protected]

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September 2, 2015

Yours,



by:

Robert J. Tolchin



(718) 855-3627


111 LIVINGSTON STREET, SUITE 1928

BROOKLYN, NEW YORK 11201

718-855-3627


COUNTY OF KINGS

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ROSENBERG,

Plaintiff,

-against-

MEILECH SCHNITZLER,

Defendants.

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Index No: ___________ / 15

SUMMONS AND COMPLAINT

Pursuant to 22 N.Y.C.R.R. § 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies

that upon information and belief and reasonable inquiry, the contentions contained in the annexed documents are not frivolous.

Dated: September 2, 2015 Signature: _________________________

rosenberg, nathan (assault)

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