This document amends a previous Notice of Intention to File a Claim regarding incidents that occurred at Kenmore East High School. It alleges that the school district, athletic director, assistant principal, and boys volleyball coach created an anti-Semitic environment. Specifically, it claims a photo was circulated depicting the coach holding a volleyball captioned "Remember Kids, Choose Volleyball and not Jews." Further, the plaintiff alleges he was punished for complaining about anti-Semitic treatment while the photo went undisciplined. The plaintiff is seeking $2 million in compensatory damages from the school district and individuals.

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KENMORE TOWN OF TONAWANDA UFSD
___________________________________________
ERIN GREEN, p/n/g CARTER OBSTEIN
Claimant, AMENDMENT/ADDENDUM TO
NOTICE OF INTENTION
TO FILE A CLAIM
- Against -
KENMORE TOWN OF TONAWANDA UFSD,
KENMORE TOWN OF TONWAWANDA BOARD OF EDUCATION,
NICK SEREDAY,
JIM BADGELY, and
JOSEPH GRECO.
Defendants.
_____________________________________________
PRELIMINARY STATEMENT
1. This is An Amendment and Addendum to the Notice of a Claim for Negligent
Hiring, Negligent Supervision, Negligent Training, Negligent Infliction of Emotional Distress,
Intentional Infliction of Emotional Distress, Title VII of the Civil Rights Act of 1964 (Religious
Discrimination), and deprivation of CARTER OBSTEIN’s constitutional rights pursuant to 42
USC §1983 dated November 2, 2018. The parties engaged in a 50-h Hearing related to that
Notice of Intention to File a Claim February 18, 2019.
PARTIES
2. Complainant ERIN GREEN, p/n/g CARTER OBSTEIN is a New York resident.
Her address is 420 Westgate Road, Kenmore New York. Her telephone number is 716.225.2237.
She is the natural mother of infant CARTER OBSTEIN, born October 22, 2002.
3. CARTER OBSTEIN, born October 22, 2002 is a student at Kenmore East High
School, part of the KENMORE TOWN OF TONAWANDA UFSD.

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4. KENMORE TOWN OF TONAWANDA UFSD is a chartered school district,
created to educate children pursuant to New York law within its geographical boundaries. It is a
distinct governmental unit, with independent taxing and debt-incurring power.
5. KENMORE TOWN OF TONWAWANDA BOARD OF EDUCATION is an
elected body established to set policy for the KENMORE TOWN OF TONAWANDA UFSD.
6. NICK SEREDAY is the Kenmore East High School Boys Volleyball Coach. He is
an employee of KENMORE TOWN OF TONAWANDA UFSD.
7. JIM BADGELY is the Athletic Director for the KENMORE TOWN OF
TONAWANDA UFSD. He is an employee of KENMORE TOWN OF TONAWANDA UFSD.
8. JOSEPH GRECO is an Assistant Principal at Kenmore East High School. He is an
employee of KENMORE TOWN OF TONAWANDA UFSD.
9. KENMORE TOWN OF TONAWANDA UFSD is liable for the actions of NICK
SEREDAY, JIM BADGELY, and JOSEPH GRECO based on the doctrine of respondeat superior.
RELEVANT FACTS
10. On approximately February 17, 2019 CARTER OBSTEIN obtained a copy of a
photo of Exhibit A, a photo of SEREDAY holding a volleyball with a caption reading, “Remember
Kids, Choose Volleyball and not Jews.”
11. Upon information and belief, this image was created by members of the Kenmore
East Volleyball Team at the express or implicit consent of or approval of SEREDAY.
12. Upon information and belief, SEREDAY knew of and approved the creation of and
dissemination of the image.
13. The DISTRICT has thus created an atmosphere that mocks my client, his Jewish
faith, and encourages Neo-Nazi threats against him.

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14. The DISTRICT, GRECO, and BADGELY reacted with approval of the Neo-Nazi
image featuring SEREDAY by refusing to investigate or punish its creators.
15. By contrast, when OBSTEIN posted a Facebook post which failed to name any
particular personnel but complained about Anti-Semitic treatment, he was pulled from class,
threatened with legal action, threatened with suspension, and told by DISTRICT personnel,
“you’re a fucking liar.”
16. The DISTRICT, by encouraging the discrimination of Anti-Semitic, Neo-Nazi
behavior, is in violation of the statutes described above, paragraph 1.
RELIEF SOUGHT
WHEREFORE Claimant demands judgment as follows:
1. $2 million in compensatory damages.
DATED: February 21, 2019
Buffalo, New York
HOUSH LAW OFFICES, PLLC
By: ___/s/ Frank Housh______________
Frank Housh, Esq.
ATTORNEY FOR ERIN GREEN,
p/n/g CARTER OBSTEIN
70 Niagara Street · Buffalo, NY 14202
p 716.362.1128 · f 716.242.3000
frank@houshlaw.com

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TO: Steven Bovina, Superintendent
KENMORE TOWN OF TONAWANDA UFSD
1500 Colvin Blvd.
Buffalo, NY 14223
BY CERTIFIED MAIL
Gina Santa Maria, District Clerk
KENMORE TOWN OF TONAWANDA UFSD
1500 Colvin Blvd.
Buffalo, NY 14223
BY CERTIFIED MAIL