NYCB Complaint

FILED: NEW YORK COUNTY CLERK 09/18/2018 01:30 PM INDEX NO.
158220/2018
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 09/18/2018
!lUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
- ------------------------------------------------- X
ALEXANDRA WATERBURY,
Index No.: ¤ 2-2-D /18
Plaintiff
-against -
AMENDED
14EW YORK CITY VERIFIED COMPLAINT
BALLET, INC.,
. ARED LONGHITANO, CHASE FINLAY,

tiCHOOL OF AMERICAN BALLET,
aMAR RAMASAR, AND, ZACH CATAZARO,
Defendants.
----------------------------- -----------X
COMPLAINT AND JURY TRIAL DEMANDED
"Plaintiff"
Plaintiff ALEXANDRA WATERBURY (hereinafter or "Ms.
Vaterbury") by and through her counsel Merson Law, PLLC, and as for her Complaint in
("NYCB"
this action against defendants NEW YORK CITY BALLET, INC. or
'
Ballet"), JARED LONGHITANO, CHASE FINLAY, AMAR RAMASAR,
CHOOL OF AMERICAN BALLET ("SAB") and ZACH CATAZARO,
(hereinafter collectively "Defendants") hereby alleges the following:
NATURE OF THE CLAIMS
. For several years, defendant NEW YORK CITY BALLET, INC. has condoned,
encouraged, fostered, and permitted an environment where its agents, servants,
employees, donor, board member, junior board member, principals and/or others
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FILED: NEW YORK COUNTY CLERK 09/18/2018 01:30 PM INDEX NO. 158220/2018
affiliated with it abused, degraded and mistreated alcohol, drugs, and women. This
fraternity-like atmosphere permeates the Ballet and its dancers and emboldens them
to disregard the law and violate the basic rights of women.
2. Indeed, defendant JARED LONGHITANO, a Junior Board Member of defendant
NEW YORK CITY BALLET, INC., and the Founding Junior Board member of the
Young Patrons Circle at defendant NEW YORK CITY BALLET, INC., actively
engaged in, encouraged, incited, instigated and participated in the exchange, of lewd,
degrading and demeaning text messages about ballet dancers. This encouraged,
incited and instigated the male Ballet dancers at NEW YORK CITY BALLET,
INC., to engage in a degrading and demeaning manner towards female ballet dancers,
including by sending the explicit text messages and images that are the subject of this
lawsuit. Mr. Longhitano did this in the scope of his employment with, and as an
agent of, defendant NEW YORK CITY BALLET, INC.
3. Specifically, plaintiff ALEXANDRA WATERBURY, a ballet dancer at other
institutions, and former student at NEW YORK CITY BALLET, INC.'s school,
defendant SCHOOL OF AMERICAN BALLET, is a victim in the Ballet's
mistreatment of women and she was subjected to horrible exploitation at the hands of
several of the Ballet's male members, including defendant CHASE FINLAY.
4. On or about May 15, 2018, the worst nightmare of every woman happened to plaintiff
ALEXANDRA WATERBURY, when she discovered that Ballet principal,
defendant CHASE FINLAY, her boyfriend of one year, had secretly been recording
and saving explicit photographs and videos of her while she was without clothing
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and/or while the two were engaged in sexual activities, and that this conduct had been
encouraged by who she thought was her friend, defendant AMAR RAMASAR.
5. It was at this time that plaintiff ALEXANDRA WATERBURY also learned that said
photos and videos had been shared with agents, servants, employees, principals of
and/or others affiliated with defendant NEW YORK CITY BALLET, INC.
6. Defendant CHASE FINLAY and/or agents, servants, employees, principals of and/or
others affiliated with defendant NEW YORK CITY BALLET, INC. shared sexual
videos and images of plaintiff, ALEXANDRA WATERBURY, and other
unknowing female victims, including other female Ballet members and students.
Specifically, the sharing of these intimate, private, and nude images of women at
defendant NEW YORK CITY BALLET, INC. occurred during work hours, on
work premises and amongst its coworkers, agents, servants, employees, donors,
principals and/or others affiliated with the Ballet.
7. The sharing of naked and explicit images of female ballet dancers, including Ms.
Waterbury amongst male Ballet dancers is a problem that appears to have occurred
exclusively at NEW YORK CITY BALLET, INC.
8. The sharing of naked and explicit images of female Ballet dancers, including Ms.
Waterbury occurred amongst male Ballet dancers because NEW YORK CITY
BALLET, INC., allowed its principals, dancers, workers, employees and others
affiliated with it to act unlawfully, disrespectfully and in disregard of the rights of
women. As a result, the male ballet dancers at NEW YORK CITY BALLET, INC.,
law"
understood that they were "above the and could do whatever they wanted to
whenever wanted to do so -- "just make sure it occurs in New York

women, they
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City"
where it could be controlled by NEW YORK CITY BALLET, INC.'s
executives and management.
9. NEW YORK CITY BALLET, INC 's actions, attitude and environment that it
created exposed its female Ballet dancers, students, other affiliated with NEW
YORK CITY BALLET, INC. and other women in New York City and elsewhere to
a group of male Ballet dancers who understood that they could degrade, demean,
mistreat and abuse, assault and batter women without consequence. What happened
to Ms. Waterbury, other female Ballet dancers and other women is directly causally
related to what NEW YORK CITY BALLET, INC., allowed these male Ballet
dancers to do, encouraged them to do, and the environment that it created over many
years.
10. Plaintiff should be praised for her bravery in the face of full-blown lack of proper
institutional control and supervision by defendant NEW YORK CITY BALLET,
INC. that allowed its agents, servants, employees, donors, principals and/or others
affiliated with it to degrade, demean and de-humanize women in the ways previously
referenced and more specifically detailed below. These details uncovered by the
plaintiff revealed just how widespread and engrained this degrading, demeaning and
disrespectful environment towards women was at defendant NEW YORK CITY
BALLET, INC.
11. Plaintiff is filing this lawsuit to stand up for her rights and to make sure that no other
woman anywhere is similarly embarrassed, humiliated, mistreated and de-humanized
no matter how large or prestigious the institution where it is allowed and encouraged
to occur.
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PARTIES OF THE CASE
12. Plaintiff ALEXANDRA WATERBURY was a nineteen year-old ballet dancer and a
former student at defendant NEW YORK CITY BALLET, INC. She is now
twenty-one years old.
13. At all times herein mentioned, defendant NEW YORK CITY BALLET, INC. was
and is a domestic not-for-profit corporation, duly organized and existing by virtue of
the law of the State of New York.
14. At all times herein mentioned, defendant NEW YORK CITY BALLET, INC. was
the owner of a production company known as The New York City Ballet located at
20 Lincoln Center Plaza, New York, New York, 10023.
15. At all times herein mentioned, defendant NEW YORK CITY BALLET, INC.
operated, managed and controlled the aforesaid production company.
16. At all times herein mentioned, defendant JARED LONGHITANO is and was a
Junior Board Member, Young Patron and Founding Junior Board member of the
Young Patrons Circle for defendant NEW YORK CITY BALLET, INC.
17. At all times herein mentioned, defendant JARED LONGHITANO was an agent,
servant and/or employee of defendant NEW YORK CITY BALLET, INC.
18. At all times herein mentioned, defendant CHASE FINLAY was employed as a
principal at defendant NEW YORK CITY BALLET, INC.
19. At all times herein mentioned, defendant CHASE FINLAY was an agent, servant
and/or employee of defendant NEW YORK CITY BALLET, INC.
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0. At all times herein mentioned, defendant AMAR RAMASAR was employed as a
1. At all times herein mentioned, defendant AMAR RAMASAR was an agent, servant
2. At all times herein mentioned, defendant ZACH CATAZARO was employed as a
3. At all times herein mentioned, defendant ZACH CATAZARO was an agent, servant
4. At all times herein mentioned, defendant SCHOOL OF AMERICAN BALLET was
and is the school for defendant NEW YORK CITY BALLET, INC.
5. At all times herein mentioned, defendant SCHOOL OF AMERICAN BALLET and
defendant NEW YORK CITY BALLET, INC., had the same founder, owner and
graduation from defendant SCHOOL OF AMERICAN BALLET was required in
order to perform at defendant NEW YORK CITY BALLET, INC.
6. At all times herein mentioned, defendants SCHOOL OF AMERICAN BALLET
and NEW YORK CITY BALLET, INC., were agents, servants and/or employees of
one another, and/or operated and/or functioned as a single entity, and/or were the alter
ego of one another.
7. At all times herein mentioned, defendant SCHOOL OF AMERICAN BALLET
required all parents of its students to sign a waiver allowing its agents, servants and/or
employees to control the manner in which the students eat, sleep and study. Apart
from this, and clearly

with this waiver, defendant SCHOOL OF AMERICAN
BALLET was in locis parentisto its students, including

Ms. Waterbury.
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8. At all times herein mentioned, all of the agents, servants, employees, donors,
principals and/or others of SCHOOL OF AMERICAN BALLET were agents,
servants and employees of defendant SCHOOL OF AMERICAN BALLET.
9. At all times herein mentioned, all of the agents, servants, employees, donors,
principals and/or others of NEW YORK CITY BALLET, INC. were agents,
servants and employees ofdefendant NEW YORK CITY BALLET, INC.
2 0. Plaintiff ALEXANDRA WATERBURY and defendant CHASE FINLAY met at
defendant NEW YORK CITY BALLET, INC., and became romantically involved.
2 1. Defendant CHASE FINLAY and other principal male dancers at defendant NEW
YORK CITY BALLET, INC., used the ballet school at defendant NEW YORK
CITY BALLET, INC., to attract, induce and lure young female dancers.
2. Ms. Waterbury, as a student at defendant NEW YORK CITY BALLET, INC.
and/or SCHOOL OF AMERICAN BALLET, met Mr. Finlay by and through the
acceptance, condoning, encouraging, facilitating, inciting and instigating its older
male dancers to interact with the young female dancers and students. Ms. Waterbury
would not have met Mr. Finlay or been subjected to the sexual assault, battery and
exploitation had it not been for defendant NEW YORK CITY BALLET, INC.
and/or SCHOOL OF AMERICAN BALLET.
2 3. It was and is foreseeable in this environment that young female dancers will be
subjected to degrading, demeaning and sexual assault, battery and abuse at the hands
of older male dancers, given their superior stature within the Company.
14. There was and is a duty on the part of the defendant NEW YORK CITY BALLET,
INC., to ballet dancers, students and others, including but not limited to, Ms.
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Waterbury given that it was encouraging and requiring its male dancers to interact
with female ballet students.
: 5. In addition, there is a special duty defendant NEW YORK CITY BALLET, INC.,
to ballet dancers, students and others given the role of the male ballet dancers and
their superior position in the ballet as compared to the female ballet students.
6. Defendant NEW YORK CITY BALLET failed to have any polices, procedures,
training, supervision or safeguards to protect these female ballet students despite
being aware of the discrepancy in stature at the Company and that male ballet dancers
used this required interaction by Defendant NEW YORK CITY BALLET with
ground."
young female dancers as a "hunting
7. Indeed, there is a video produced and disseminated by Defendant NEW YORK
CITY BALLET with defendants CHASE FINLAY and AMAR RAMASAR,
wherein they both boast that they love being with the women of defendant NEW
YORK CITY BALLET, INC. This was one of many warnings that defendant NEW
YORK CITY BALLET, INC., ignored that it was placing the female ballet dancers
in a dangerous and unsafe position at the hands of the male Ballet dancers.
FACTS OF THIS CASE
2 8. For many years, defendant NEW YORK CITY BALLET, INC., has allowed,
condoned, encouraged and permitted its male dancers to abuse, assault, degrade,
demean, de-humanize and mistreat its female dancers and other women.
2 9. This out of control fraternity-like atmosphere was allowed to permeate all levels of
NEW YORK CITY BALLET, INC., so long as the institution continued to sell
tickets and was profitable.
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0. When its employees and principals received awards and other accolades, NEW
YORK CITY BALLET, INC., benefitted from this, but when the same or other
employees and principals acted unlawfully, recklessly or in otherwise offensive and
degrading means towards women, the NEW YORK CITY BALLET, INC., did not
rug."
act to stop this conduct and merely swept it "under the
Hew York City Ballet has a History of Condoning, Emboldeñing and Encouraging
14ale Ballet Dancers to Sexually Assault, Batter. Demeâñ and Abuse Women
1. By way of example only, a NEW YORK CITY BALLET, INC. principal dancer
was sent to rehab after law enforcement became involved due to his substance abuse
and domestic violence against a female corps member at NEW YORK CITY
BALLET, INC, but he returned after a week or so and now continues to be employed
by NEW YORK CITY BALLET, INC without repercussion.
2. This sent the message to Mr. Finlay and other NEW YORK CITY BALLET, INC.
male dancers and others that it was acceptable to NEW YORK CITY BALLET,
INC. to abuse substances and degrade, demean, dehumanize and physically abuse
women, including one of its own employees.
e 3. one of the program Jon asked Mr. about

Indeed, directors, Stafford, frequently Finlay
his partying and alcohol use because he smelled like alcoholic beverages and yet,
NEW YORK CITY BALLET, INC. buried its head in the sand without
investigating Mr. Finlay s conduct.
4. This sent the message to Mr. Finlay

and other NEW YORK CITY BALLET, INC.
male dancers that excess substance abuse and its consequences were tolerated and
acceptable to NEW YORK CITY BALLET, INC.
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45. Likewise, on a recent trip to Washington D.C., several members of defendant NEW
YORK CITY BALLET, INC., including, but not limited to, defendant CHASE
FINLAY were fined over $150,000 for destroying a hotel room at a party they hosted
with underage girls to whom they provided and plied with drugs and alcohol.
46. In response to this incident, rather than suspend or discipline any of these employees,
management of defendant NEW YORK CITY BALLET, INC. and its agents,
servants, employees, principals and/or others encouraged this illicit conduct, ordering
that they should stick to this type of behavior when they are in New York City since it
would be easier to control. This type of leadership is exactly what allowed for the
creation of a sexually charged environment where women were second-class citizens
and this culture that involved the sharing of non-consensually obtained explicit
images of many women.
47. This lack of discipline by defendant NEW YORK CITY BALLET, INC., despite
clear knowledge of past incidents and it was foreseeable that future similar incidents
where mis-treatment, assault and/or battery of woman would occur.
48. Defendant JARED LONGHITANO, a Junior Board Member of defendant NEW
YORK CITY BALLET, INC., and the Founding Junior Board member of the
Young Patrons Circle at defendant NEW YORK CITY BALLET, INC., actively
engaged in, encouraged, incited, instigated and participated in the exchange, of lewd,
degrading and demeaning text messages about ballet dancers.
49. This encouraged the male Ballet dancers at NEW YORK CITY BALLET, INC., to
engage in a degrading and demeaning manner towards female ballet dancers, and
other women affiliated with NEW YORK CITY BALLET, INC. and SCHOOL
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OF AMERICAN BALLET, including by sending the explicit text messages and
images that are the subject of this lawsuit.
:;0. Mr. Longhitano was also on the Young Patrons Host Committee and as such, he
hosted, managed, planned and sponsored events for defendant NEW YORK CITY
BALLET, INC.
!il. According to the website of defendant NEW YORK CITY BALLET, INC., as part
of the Young Patrons Circle for defendant NEW YORK CITY BALLET, INC., Mr.
Longhitano received "Complimentary access for you to Young Patrons Circle events,
parties,"
including post-performance "Exclusive invitation to a private Art Series
dancers," pre-
reception with the artists and "Complimentary invitations to
presentations,"
performance chats with dancers and Inside NYCB "Discounted class
East,"
at Ballet Academy and "Invitation to a special event hosted by a member of the
Directors."
NYC Ballet Board of
2. Defendant NEW YORK CITY BALLET, INC., held Mr. Longhitano out to the
World as one of its agents, servants and/or employees, and there are images of the
American Ballet Theatre Junior Council hosting Mr. Longhitano, given his position
with NEW YORK CITY BALLET, INC.
3. Thereafter, Mr. Longhitano wrote to Mr. Finlay that "we should get like half a kilo
them."
and pour it over the ABT girls and just violate He continued that "I bet we
animals"
could tie some of them up and abuse them like farm to which Mr. Finlay
are."
added "or like the sluts they
4. NEW YORK CITY BALLET, INC. was well aware of Mr. Longhitano's conduct
as he hosted NYCB parties where excess alcoholic beverages consumption is
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encouraged to the point where his microphone had to be cut during a speech. Yet,
NEW YORK CITY BALLET, INC continued to take his money, allowed him to
attend events regardless of his behavior, and to have unfettered and unsupervised
access to younger ballet dancers in an inferior position with defendant to him.
INC. to abuse substances and degrade, demean, dehumanize and sexually abuse
WOmen.
6. Mr. Longhitano's conduct, including. but not limited to, the text messages that he sent
to Mr. Finlay encouraged, incited and/or instigated him, and others at NEW YORK
CITY BALLET, INC., to engage in a degrading and demeaning manner towards
female ballet dancers, including by sending the explicit text messages and images that
are the subject of this lawsuit.
INC. to degrade, demean, dehumanize and sexually abuse women, including by
sending sexual, explicit and intimate text messages, including, but not limited to the
ones that Ms. Waterbury has seen and are the subject to this lawsuit.
8. There also have been past instances of men sexually and physically abusing women at
NEW YORK CITY BALLET, INC that have been swept under the rug, offering
carte blanche for the other male NYC ballet employees. By way of example only, the
claims about a male NEW YORK CITY BALLET, INC principal raping a female
NEW YORK CITY BALLET, INC. soloist in Vail and assaulting another female
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corps member at NEW YORK CITY BALLET, INC. However, NEW YORK
CITY BALLET, INC. continued to employee this male Ballet dancer without any
repercussions or discipline. This incident and the Company s lack of response was
well-known and discussed throughout NEW YORK CITY BALLET, INC.
!9. This sent the message to Mr. Finlay and other NEW YORK CITY BALLET, INC.
INC. to abuse substances and degrade, demean, dehumanize and sexually abuse,
assault and batter women, including but not limited to the dissemination of images of
Ms. Waterbury and others without their consent.
(0. Many NEW YORK CITY BALLET, INC., individuals at many different levels,
including multiple male principals, dancers, students and a donor have been involved
in demeaning and unlawful activity towards women that have been allowed to
continue to this conduct with impunity.
( 1. As such, NEW YORK CITY BALLET, INC. condoned, authorized, encouraged,
incited and instigated defendant CHASE FINLAY and its other agents, servants,
employees, donor, junior board member, principals and/or others to the degrading,
de-humanizing and mistreatment of women, including, but not limited to taking
explicit and sexual images of plaintiff without her consent and disseminating these
images to other Ballet dancers without her consent.
(2. Having dealt with events like the above-referenced, defendant NEW YORK CITY
BALLET, INC. was certainly on notice that defendant CHASE FINLAY and/or
agents, servants, employees, donor, junior board member, principals and/or others
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had a propensity to engage in illicit conduct including, but not limited to, sexually
assaulting and exploiting women.
(i3. And there was the resignation of NEW YORK CITY BALLET, INC. artistic
director Peter Martins, effective

January 1, 2018. This was after there were
complaints of physical, verbal and sexual abuse. Of course, the NEW YORK CITY
BALLET, INC. determined that these claims based on conduct that occurred in 2017
and prior thereto were unfounded.
INC. to abuse substances and degrade, demean, dehumanize and sexually abuse
WOmen.
(i5. NEW YORK CITY BALLET, INC. failed to understand, appreciate or care that it
was accepting, condoning, encouraging and emboldening, inciting

and instigating its
male dancers to act lawlessly, and abuse and de-humanize women, which caused its
male dancers to circulate naked, intimate, private, explicit and sexual pictures of
women, including Ms. Waterbury.
(i6. Clearly, defendant NEW YORK CITY BALLET, INC. and/or its agents, servants,
employees, donor, junior board member, principals and/or others affiliated with it had
actual notice that its male dancers were engaging in unlawful, demeaning and
degrading conduct towards young women, yet the Ballet did absolutely nothing to
stop it.
( 7. Upon information and belief, defendant CHASE FINLAY and other male Ballet
dancers, workers and others affiliated with NEW YORK CITY BALLET, INC.,
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conspired, plotted and planned at NEW YORK CITY BALLET, INC., to exchange
amongst each other nude, sexual and/or explicit images of female ballet dancers,
students, former students and others affiliated with the Ballet, their spouses and
significant others, and other women to each other inside the workplace.
( 8. Ms. Waterbury would not have had her intimate, private, explicit and sexual images
disseminated by and amongst NEW YORK CITY BALLET, INC. workers had
NEW YORK CITY BALLET, INC. properly supervised these male dancers and
acted appropriately in response to prior instances where women were abused and/or
mistreated, and their failure to do so encouraged and emboldened Mr. Finlay and
other male Ballet dancers to further degrade, dehumanize and/or mistreat women,
including Ms. Waterbury.
( 9. This conduct by defendant CHASE FINLAY and/or agents, servants, employees,
donor, junior board member, principals and/or others of defendant NEW YORK
CITY BALLET, INC. on company time and property, amongst its principal male
dancers, imputes liability on defendant, NEW YORK CITY BALLET, INC., as an
employer is liable for torts committed by employees acting within the scope of
employment.
0. The actions of defendant CHASE FINLAY and/or agents, servants, employees,
donor, junior board member, principals and/or others of defendant NEW YORK
CITY BALLET, INC. impute liability on defendant NEW YORK CITY BALLET,
INC. as the tortious conduct was foreseeable and a natural incident of the
employment.
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'l. This is no different than a principal telling an agent to act unlawfully, or that it is ok
to do so, and the agent then in fact does so. The principal, in this case, NEW YORK
CITY BALLET, INC., is responsible for

creating the circumstances, environment
and state-of-mind that caused Mr. Finlay to act in a despicable, demeaning and
unlawful manner towards Ms. Waterbury.
lds. Waterbury and other female Ballet Dancers and Students Had Sexual. Explicit
and Naked Pictures Shared By and Amôñgst New York City Ballet Agents, Servants
and/or Employees
"2. Ms. Waterbury met Mr. Finlay by and through NEW YORK CITY BALLET, INC.,
and/or SCHOOL OF AMERICAN BALLET when she was a student there. NEW
YORK CITY BALLET, INC., and/or SCHOOL OF AMERICAN BALLET was
in locis parentis to Ms. Waterbury and repeatedly failed in their duty to protect her.
"3. Ms. Waterbury would not have met Mr. Finlay and been subjected to the
aforementioned unlawful conduct but for the NEW YORK CITY BALLET, INC.,
and/or SCHOOL OF AMERICAN BALLET.
'4. NEW YORK CITY BALLET, INC. allowed, condoned, encouraged, incited and/or
instigated older male Ballet dancers and others affiliated with the NEW YORK
CITY BALLET, INC. to have unfettered and/or unsupervised access to the younger
female dancers in the school who were in an inferior stature and/or position at
defendants.
'5. NEW YORK CITY BALLET, INC. did not have any policies, procedures,
protocols, guidelines, rules and/or regulations regarding these interactions.
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6. NEW YORK CITY BALLET, INC. was aware that the older male Ballet dancers
and others affiliated with the NEW YORK CITY BALLET, INC. were sexually
abusing, degrading and exploiting the younger female dancers in the school.
C7. The sharing of intimate, naked, sexual and/or explicit images of female ballet dancers
and other women were done by a

group of male Ballet dancers and others solely
affiliated with NEW YORK CITY BALLET, INC.
8. Indeed, on September 3, 2017, defendant CHASE FINLAY sent a photograph of
plaintiff naked captioned: "You have any pictures of girls you've f*cked? I'll send
you some got ballerina girls I've made scream and squirt".
9. The conduct continued on September 8, 2017, when another male employee of
defendant NEW YORK CITY BALLET, INC., shared illicit photographs of a
female Ballet member to defendant CHASE FINLAY who in turn, sent them to a
man engaged to another female Ballet member. Later that same day, defendant
CHASE FINLAY shared more illicit photographs of female ballet dancers with
others affiliated with NEW YORK CITY BALLET, INC. on the text chain.
t 0. In fact, Junior Board Member at NEW YORK CITY BALLET, INC., Mr.
Loughitano sent a text to Zach Catazaro and Mr. Finlay where he wrote "We should
get like half a kilo and pour it over the ABT girls and just violate them. I bet we
animals."
could tie some of them up and abuse them like farm Mr. Finlay added "Or
are."
like the sluts they Mr. Loughitano continued that "Yeah. I want them to watch
me destroy one of their friends. And they know they're next. I bet we could triple
."
team . . . another identified girl or woman.
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::1. On Friday, September 8, 2017, the husband of an NEW YORK CITY BALLET,
INC. corps member shared naked images of his wife with Mr. Finlay, who sent them
to the fiancee of another NEW YORK CITY BALLET, INC. dancer. At 10:40 am,
this individual then sent pictures of this NEW YORK CITY BALLET, INC. soloist
with her sister of American Ballet Theatre to Mr. Finlay and wrote "Delete those
lol." out."
pictures "Seriously though that one .... can't get
:2. On October 9, 2017, Mr. Finlay shared explicit images of Ms. Waterbury and wrote,
"That girl in the picture is 19! She is a super hot model that I am wrecking every
night!"
I'm trying to get a sex tape with her cause I know that shot would sell. She is
12+"
a fucking "I also just fucked a 20 year old ballerina and her sister! That was
incredible!"
my first threesome with family members. It was
:3. Mr. Finlay inquired of Mr. Catazaro to "Lemme see another picture of [another
former SAB student]. Ill never share with anyone. She honestly has the perfect
body."
Mr. Catazaro responded "Yeah man it's changed though. LOL the pics I sent
Joan,"
you were from when she was 18. She has gone downhill ever since and then
sent a picture of this former SAB's student's bare breasts to Mr. Finlay.
4. Mr. Catazaro wrote "That's the only other one i have without a face. I can't give you
LOL."
one with a face. Mr. Finlay responded "Thats prime time for women. It
reason."
might sound creepy but 18 is the age of consent for a Mr. Catazaro replied,
18-22."
"Word up bro,
fuck"
5. Mr. Catazaro then suggested to Mr. Finlay "You need to a specifically
identified NYCB Corps member and Mr. Finlay wrote "Fucking hell man. We should
straight up ask her some time and leave her no choice. What girl would say no to that
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offer?"
Mr. Catazaro responded, "You should! I seriously I can't But I would feel too
myself."
bad about Mr. Finlay followed up by writing, "I will and tape it. That
persuasion." yes."
would be ultimate sexual Mr. Catazaro wrote, "Fuuuuck Lol Mr.
Finlay continued, "I feel like she is down to fuck though. Apparently she used to ride
everything...."
some kids dick every day at sab. Started taking birth control and Mr.
dick."
Catazaro replied "Well make sure she's riding your Mr. Finlay responded,
hotter."
"That makes it
t 6. Mr. Finlay also provided a picture of Ms. Waterbury perfonning a sexual act on him
and sent it via text message to former SAB student, Craig Hall.
t 7. On May 2, 2018, Mr. Finlay sent a different picture of Ms. Waterbury naked to
former NYCB student, Mr. Hall.
t:8. Mr. Finlay

then sent another picture of Ms. Waterbury engaged in a sexual act, who
101."
responded, "I can't stop looking at Alex's tits Mr. Finlay
wrote "Well its all
Enjoy."
yours now. Mr. Hall responded that "I will trust me, just as u know, always
want more. I'm going to get u some good shit I promise. Some close up, slow-mo
shit."
dick in pussy
9. Mr. Hall provided Mr. Finlay

with a full-body naked picture of an NEW YORK
CITY BALLET, INC., Soloist and wrote via text message "This is good, right? Full
frontal." Dude!."
Mr. Finlay responded "That is so hot
0. On April 9, 2018, from 7:17 am to 1:18 pm, Mr. Finlay texted Mr. Ramasar about his
sexual experiences with him and a female NEW YORK CITY BALLET, INC.,
Corps member.
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91. On May 21, 2018, Mr. Ramasar then sent a picture of a female NEW YORK CITY
BALLET, INC., Corps member bare-breasted to Mr. Finlay after he asked Mr.
her."
Ramasar to "Send me that pic of
92. That same day, Mr. Finlay

sent a picture of the bare breasts of a female from the
fucking!!"
American Ballet Theatre and Mr. Ramasar texted "You
93. Mr. Ramasar sent another picture of the NEW YORK CITY BALLET, INC.,
:)"
Corps member naked, and wrote "Bottom half us way better!!;
more."
94. Mr. Finlay responded, "Already seen that one, I know you have Mr.
Ramasar then sent a picture of the NEW YORK CITY BALLET, INC., Corps
member's vagina to Mr. Finlay.
photos/videos!!;)"
95. Mr. Ramasar then texted Mr. Finlay "I love you! Text me those
and Mr. Finlay sent images to Mr. Ramasar of Ms. Waterbury's bare breasts and
performing a sexual act.
96. On May 23, 2018, Mr. Finlay shared another picture of Ms. Waterbury with a former
SAB student who is now a dancer at Pacific Northwest Ballet.
97. Also on May 21, 2018, Mr. Finlay wrote to Mr. Ramasar referring to a female NEW
YORK CITY BALLET, INC., Corps member, "Like actually she might be a little
pissed just cause we are talking to each other while we are horny and then taking it to
."
the level of showing each other pictures of other women . .
98. This establishes that Mr. Finlay and Mr. Ramasar were aware that these women did
not consent to the sharing of their explicit images.
99. Likewise, Mr. Finlay also had a text exchange with former Ballet student, Mr. Hall,
pictures?"
wherein her wrote "should I just show everyone these To which, Mr. Hall
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writes "Noooooo. Lets keep in between us. I feel like in this respect we have a
different relationship
than we do with them. Feel like it should be our special shared
together...."
thing. We don't share
anything we shared with each other, just enjoy it
00. NEW YORK CITY BALLET, INC. is a

breeding ground for sexual exploitation
and degradation where the principal dancers and others are allowed to objectify and
abuse women however they want.
01. On or about May 15, 2018, plaintiff ALEXANDRA WATERBURY discovered
that defendant CHASE FINLAY, her boyfriend of one year, had secretly been
recording and saving intimate photographs and videos of her while she was without
clothing and/or while the two were engaged in sexual activities.
02. It was at this time that plaintiff ALEXANDRA WATERBURY also learned that
said photos and videos had been shared with agents, servants, employees, principals
and/or others of defendant NEW YORK CITY BALLET, INC.
03. Defendant CHASE FINLAY and/or agents, servants, employees, donors,
principals and/or others of defendant NEW YORK CITY BALLET, INC. shared
graphic videos and images of plaintiff, ALEXANDRA WATERBURY, and other
unknowing victims, including other female ballet members and other students.
Specifically, the sharing

of these intimate, private, and nude images of women,
including Ms. Waterbury at defendant NEW YORK CITY BALLET, INC.
occurred during work hours, on work premises and amongst its coworkers, agents,
servants, employees, donors, principals and/or others affiliated with defendant NEW
YORK CITY BALLET, INC.
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Waterbury amongst male ballet dancers occurred exclusively at NEW YORK CITY
BALLET, INC.
Waterbury occurred amongst male Ballet dancers because NEW YORK CITY
BALLET, INC., allowed its principals, dancers, workers, employees and others to
act unlawfully, disrespectfully and to assault, batter and abuse women. As a result,
the male ballet dancers at NEW YORK CITY BALLET, INC., understood that they
law"
were "above the and could do whatever they wanted to women, whenever they
-- City,"
wanted to do so "just make sure it occurs in New York according to its
senior leadership and management.
06. NEW YORK CITY BALLET, INC.'s actions, attitude and environment that it
created exposed its female ballet dancers and other women in New York City and
elsewhere to a group of male ballet dancers who understood that they could assault,
batter degrade and abuse women without consequence. What happened to Ms.
Waterbury, other female ballet dancers and other women is directly causally related
to what NEW YORK CITY BALLET, INC., allowed, encouraged, incited and/or
instigated these male Ballet dancers to do and the environment that it created over
many years. This abuse, assault and battery of women and hard-partying lifestyle of
the male Ballet dancers was accepted, condoned, encouraged, incited, instigated
and/or ratified by defendant NEW YORK CITY BALLET, INC.
07. Ms. Waterbury never consented to the explicit video and photographs of her being
taken and defendant CHASE FINLAY and/or agents, servants, employees, principals
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and/or others of defendant NEW YORK CITY BALLET, INC. never asked for and
never received permission from plaintiff to share these graphic photos and videos.
08. In fact, plaintiff clearly repeatedly and unequivocally rejected defendant CHASE
FINLAY's attempts to film her. Nonetheless, defendant CHASE FINLAY not only
took images and live photos of plaintiff's naked body and of her performing sexual
acts, but also shared them with agents, servants, employees, principals and/or others
at defendant NEW YORK CITY BALLET, INC. without her consent.
09. These messages represent a just small snapshot of the abhorrent behavior that has
completely engulfed the defendant NEW YORK CITY BALLET, INC.
"one-off"
Furthermore, this behavior was far from a as the ballet had ample notice
that the mistreatment, sexualization and assault, abuse and battery of women had been
ongoing long before being on notice of this claim and yet, it did nothing to intervene
and what happened to Ms. Waterbury was caused directly by the failures of NEW
YORK CITY BALLET, INC to intervene and appropriately supervise its principals,
employees, agents, servants and/other others. Rather NEW YORK CITY BALLET,
INC. allowed, condoned, encouraged, emboldened and/or permitted its principal
dancers that they could do whatever they wanted so long as it was in New York City.
If the NEW YORK CITY BALLET, INC. had simply heeded the complaints of
past female ballet members and made some real change to their policies, oversight
and supervision, plaintiff's intimate images would not have been taken and
disseminated.
'supervision'
10. Said culture was allowed to fester under the of defendant NEW
YORK CITY BALLET, INC., its agents, servants, employees, donor, junior board
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member, principals and/or others and this conduct that was allowed to go on, was
taking place not only during the hours when these individuals were on the clock at
defendant NEW YORK CITY BALLET, INC.'s, but also on the actual, physical
premises of the Ballet itself.
11. Defendant CHASE FINLAY and other male ballet dancers at defendant NEW
YORK CITY BALLET, INC. made no effort whatsoever to hide what they were
doing on work premises, during work time, and amongst Ballet employees, and it is
clear that defendant NEW YORK CITY BALLET, INC. and/or its agents, servants,
employees, donor, junior board member, principals and/orothers affiliated with ithad
actual notice that its male dancers were unlawfully disseminating sexual and explicit
images of female ballet dancers and other women, yet the Ballet did absolutely
nothing to
stop
it. Defendant NEW YORK CITY BALLET, INC. also knew or
should have known that its agents, servants, employees and principals and male Ballet
dancers had and would sexually abuse, assault, batter and unlawfully image and
disseminate images of women including, but not limited to, Ms. Waterbury, without
consent.
12. Defendant NEW YORK CITY BALLET, INC.'s control over defendant
CHASE FINLAY and its other agents, servants, employees, donors, principals
and/or others who were engaged in this conduct is clear as by August 28, 2018,
defendant NEW YORK CITY BALLET, INC., suspended two principals, Amar
Ramasar and Zachary Catazaro, both of whom sent and received photos to and from
"resigned"
defendant CHASE FINLAY. Defendant CHASE FINLAY suddenly as
well. Clearly, defendant NEW YORK CITY BALLET, INC. always maintained
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the ability to discipline and control defendant CHASE FINLAY and the other agents,
servants, employees, donors, principals and/or others in his position, like Ramasar
and Catazaro, yet only did so immediately prior to these incidents becoming public.
13. Further
substantiating
its control over, and the unlawful conduct of Mr. Ramasar
and Mr. Catazaro, September 15, 2018, defendant NEW YORK CITY BALLET,
INC., terminated the employments of Mr. Ramasar and Mr. Catazaro and claimed in
a statement that it has "no higher obligation than to ensure that our dancers and staff
have a workplace where they feel respected and valued, and we are committed to
Ballet."
providing that environment for all employees of New York City
14. To the contrary, it is clear that defendant NEW YORK CITY BALLET, INC.
has been aware of its toxic and horrible environment towards women for some time
yet have only now decided to act once their failures were about to be, and after they
became, public.
15. As a result of the

foregoing conduct, plaintiff has suffered from and will continue
to endure permanent psychological trauma for the rest of her life.
16. Plaintiff's reputation as a professional ballet dancer and model has been ruined
due to the unlawful conduct of the defendants herein named.
AS AND FOR A FIRST CAUSE OF ACTION FOR NEGLIGENCE

AS TO DEFENDANT NEW YORK CITY BALLET. INC. AND
SCHOOL OF AMERICAN BALLET
17. Plaintiff repeats, reiterates each and every allegation contained in those
paragraphs of the complaint marked and designated 1. through 116., inclusive with
the same force and effect as if hereafter set forth at length.
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18. At all times herein mentioned, defendants NEW YORK CITY BALLET, INC.
and SCHOOL OF AMERICAN BALLET were under a duty in locis parentis to
safeguard Ms. Waterbury and other students, to operate control, supervise, manage
and maintain the premises utilized in the carrying out of performance which
defendant CHASE FINLAY took part in a safe, proper and lawful manner so that
plaintiff would not be caused to sustain personal injuries, it created an unsafe and
dangerous condition, the aforementioned unlawful conduct was foreseeable and
incident of employment, its agents, servants and/or employee condoned, endorsed,
encouraged, incited, instigated the dissemination of Ms. Waterbury's and other
women's images, and it failed in its duty to provide a safe, proper and lawful work
environment rather than a place where laws were repeatedly and routinely broken,
and said defendants were under a duty to employ competent and properly trained
agents, servants, employees, donor, junior board member, principals and/or others
with the proper training and experience so plaintiff would not be caused to sustain
personal injuries while under the supervision of defendant NEW YORK CITY
BALLET, INC. and SCHOOL OF AMERICAN BALLET both inside and outside
the aforesaid premises.
19. At all times herein mentioned, defendants NEW YORK CITY BALLET, INC.
and SCHOOL OF AMERICAN BALLET were on notice that its agents, servants,
employees, principals and others affiliated with the Ballet, acted unlawfully towards,
assaulted, battered, abused and/or mistreated women and that it was foreseeable that
its agents, servants, employees, principals and others affiliated with the Ballet, would
continue to do so, including, but not limited to, the unlawful dissemination of
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intimate, explicit, and sexual images of women, including Ms. Waterbury without her
consent.
20. As such, defendants NEW YORK CITY BALLET, INC. and SCHOOL OF
AMERICAN BALLET had a duty to no longer encourage, condone and/or permit
its agents, servants, employees, principals and others affiliated with the Ballet, to act
unlawfully towards, assault, batter, abuse and/or mistreat women, including Ms.
Waterbury.
21. Defendants NEW YORK CITY BALLET, INC. and SCHOOL OF
AMERICAN BALLET also had a duty to not create an environment and
circumstances where its agents, servants, employees, principals and others affiliated
with the Ballet, could, should and would act unlawfully towards, assault, batter, abuse
and/or mistreat women, including Ms. Waterbury.
that defendant CHASE FINLAY, principal at defendant NEW YORK CITY
BALLET, INC., and her boyfriend of one year, had secretly been recording and
saving intimate photographs and videos of her while she was without clothing
and/or
while the two were engaged in sexual activity.
23. Said occurrences were due to the carelessness and negligence of the defendant
NEW YORK CITY BALLET, INC., and SCHOOL OF AMERICAN BALLET
and/or their agents, servants, employees, donors, principals and/or others affiliated
with it in
failing
to render proper supervision over its other agents, servants,
employees, donor, junior board member, principals and/or others affiliated with it, all
27 of 59
without any fault or lack of care on the part of plaintiff ALEXANDRA
WATERBURY.
24.
By reason of the
foregoing carelessness and negligence of the defendant NEW
YORK CITY BALLET, INC., and/or its agents, servants, employees, donors,
principals and/or others affiliated with it, plaintiff ALEXANDRA WATERBURY
sustained serious and severe psychological and emotional distress, mental anguish,
embarrassment, and humiliation, and upon information and belief these injuries are of
a permanent and lasting nature; that said plaintiff was confined to her bed, home,
and/or various medical institutions as a result thereof, and was incapacitated from
attending her regular activities; and there was caused to be expended sums of money
for medical and hospital care on her behalf.
25. By reason of the foregoing, plaintiff, ALEXANDRA WATERBURY, is entitled
to compensatory damages from defendants NEW YORK CITY BALLET, INC.,
and SCHOOL OF AMERICAN BALLET in such sums as a jury would find fair,
just, and adequate, and plaintiff, ALEXANDRA WATERBURY, is entitled to
punitive damages from defendants and SCHOOL OF AMERICAN BALLET and
NEW YORK CITY BALLET, INC., in such sums as a jury would fmd fair, just,
and adequate, to deter others from similarly acting as defendants have herein.
26. The amount of damages sought exceeds the jurisdiction of all lower courts which
would otherwise have jurisdiction.
27. This action falls within exceptions to Article 16 of the C.P.L.R.
28 of 59
AS AND FOR A SECOND CAUSE OF ACTION FOR NEGLIGENT HIRING.

TRAINING. RETENTION AND/OR SUPERVISION AS TO
DEFENDANT NEW YORK CITY BALLET. INC. AND
DEFENDANT SCHOOL OF AMERICAN BALLET
29. At all times herein mentioned, defendants NEW YORK CITY BALLET, INC.,
and/or SCHOOL OF AMERICAN BALLET knew or should have known that their
agents, servants, employees, donor, junior board member, principals and/or others,
including, but not limited to, defendant CHASE FINLAY, JARED LONGHITANO
and AMAR RAMASAR and other, were engaged in acts that are unlawful, creating
an environment for individuals such as plaintiff ALEXANDRA WATERBURY to
be assaulted, battered, sexually abused and had her explicit, intimate and sexual
images disseminated without her consent.
30. In fact, defendants NEW YORK CITY BALLET, INC., and/or SCHOOL OF
AMERICAN BALLET and/or their agents, servants and/or employees condoned,
endorsed, ratified, encouraged, incited and/or instigated its agents, servants and/or
employees, including but not limited to defendants herein, to unlawfully take, take
and/or disseminate images of Ms. Waterbury and other women without consent.
31. Indeed, defendants NEW YORK CITY BALLET, INC., and/or SCHOOL OF
AMERICAN BALLET and/or their actively participated and/or were involved in
misconduct of Mr. Longhitano, Mr. Finlay and Mr. Ramasar.
32. Defendants NEW YORK CITY BALLET, INC., and/or SCHOOL OF
AMERICAN BALLET and/or their agents, servants and/or employees were aware
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that Mr. Longhitano, Mr. Finlay and Mr. Ramsar were unfit to meet invitees who
were likely to come into contact with them by and through the Ballet, including Ms.
Waterbury.
and/or SCHOOL OF AMERICAN BALLET and/or their agents, servants and/or
employees knew or should have known that ambivalence, indifference, condoning,
pennitting, allowing and/or encouraging, inciting and/or instigating its agents,
servants, employees, donor, junior board member, principals and/or others, to act
unlawfully towards and assault, abuse, batter and mistreat women, would cause its
agents, servants, employees, donors, principals and/or others affiliated with it,
including, but not limited to, defendant CHASE FINLAY, to act unlawfully towards
and assault, abuse, batter and mistreat women, including, but not limited to Ms.
Waterbury, by disseminating explicit, sexual and naked images of her without
consent.
34. At all times herein mentioned,defendants NEW YORK CITY BALLET, INC.,
and/or SCHOOL OF AMERICAN BALLET and/or failed to properly train and/or
supervise their agents, servants, employees, donors, principals and/or others affiliated
with the Ballet, including, but not limited to, defendant CHASE FINLAY.
and/or SCHOOL OF AMERICAN BALLET and/or their agents, servants and/or
employees placed Mr. Longhitano, Mr. Finlay and Mr. Ramasar in the position to
cause this foreseeable harm, to which Ms. Waterbury would have been spared had
NYCB taken reasonable care in its decisions concerning the hiring, retention and
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supervision of its agents, servants and/or employees, including the defendants named
herein.
36. At all times herein mentioned, NYCB was on notice of relevant tortious
propensities of Mr. Longhitano, Mr. Finlay and Mr. Ramasar.
37. As an employer, defendants NEW YORK CITY BALLET, INC., and/or
SCHOOL OF AMERICAN BALLET and/or their agents, servants and/or
employees were required to avoid the employment or retention of employees who
were known or should have been known to be unfit by reason of objectionable
character, temperament or propensity rendering them likely to assault, batter and/or
abuse women, including

Ms. Waterbury, by disseminating explicit, sexual and naked
images ofher without consent.
38. Due to the failure of defendants NEW YORK CITY BALLET, INC., and/or
SCHOOL OF AMERICAN BALLET and/or their agents, servants and failures to
properly hire, train, retain and supervise their agents, servants, employees, donors,
principals and/or others affiliated with the Ballet, including, but not limited to,
defendant CHASE FINLAY, as set forth above, the private, intimate and explicit
images of Ms. Waterbury were shared and disseminated amongst defendants NEW
YORK CITY BALLET, INC., and/or SCHOOL OF AMERICAN BALLET
and/or their agents, servants, employees, donors, principals and/or others affiliated
with the Ballet.
39. By reason of the foregoing carelessness and negligence of the defendants NEW
YORK CITY BALLET, INC., and/or SCHOOL OF AMERICAN BALLET
and/or their agents, servants, employees, donors, principals and/or others, plaintiff
31 of 59
ALEXANDRA WATERBURY sustained serious and severe psychological and
emotional distress, mental anguish, embarrassment, and humiliation, and upon
information and belief these injuries are of a permanent and lasting nature; that said
plaintiff was confined to her bed, home, and/or various medical institutions as a result
thereof, and was incapacitated from attending

her regular activities; and there was
caused to be expended sums of money for medical and hospital care on her behalf.
to compensatory damages from defendants NEW YORK CITY BALLET, INC.,
and/or SCHOOL OF AMERICAN BALLET in such sums as a jury would find fair,
just, and adequate, and plaintiff, ALEXANDRA WATERBURY, is entitled to
punitive damages from defendants NEW YORK CITY BALLET, INC., and/or
SCHOOL OF AMERICAN BALLET in such sums as a jury would find fair, just,
and adequate, to deter others from similarly acting as defendants have herein.
AS AND FOR A THIRD CAUSE OF ACTION FOR NEGLIGENCE

AS TO DEFENDANT JARED LONGHITANO
44. At all times herein mentioned, defendant JARED LONGHITANO had a duty to
Ms. Waterbury, female Ballet dancers, students and other women to not condone,
32 of 59
encourage and/or incite the male Ballet dancers, including Mr. Finlay to degrade,
demean, sexual assault, abuse and batter women, including but not limited to the
taking, sending, sharing and disseminating sexual, explicit and intimate images of
Ms. Waterbury and other female Ballet dancers, students and others, and breached
that duty by his conduct which condoned, encouraged and/or incited male Ballet
dancers to degrade, demean, sexual assault, abuse and batter women, including
but
not limited to the taking, sending, sharing

and disseminating sexual, explicit and
intimate images of Ms. Waterbury and other female Ballet dancers, students and
others.
BALLET, INC., and her boyfriend of one year, had without her consent, secretly
been recording and saving and sharing intimate photographs and videos of her while
she was without clothing and/or while the two were engaged in sexual activity.
JARED LONGHITANO in condoning, encouraging and inciting male Ballet
dancers to degrade, demean, sexual assault, abuse and batter women, including but
not limited to the taking, sending, sharing and disseminating sexual, explicit and
intimate images of Ms. Waterbury and other female Ballet dancers, students and
others, all without any fault or lack of care on the part of plaintiff ALEXANDRA
WATERBURY.
47. By reason of the foregoing carelessness and negligence of the defendant JARED
LONGHITANO, plaintiff ALEXANDRA WATERBURY sustained serious and
33 of 59
severe psychological and emotional distress, mental anguish, embarrassment, and
humiliation, and upon information and belief these injuries are of a permanent and
lasting nature; that said plaintiff was confined to her bed, home, and/or various
medical institutions as a result thereof, and was incapacitated from attending her
regular activities; and there was caused to be expended sums of money for medical
and hospital care on her behalf.
to compensatory damages from defendant JARED LONGHITANO, in such sums as
a jury would find fair, just, and adequate, and plaintiff, ALEXANDRA
WATERBURY, is entitled to punitive damages from defendant JARED
LONGHITANO, in such sums as a jury would find fair, just, and adequate, to deter
others from similarly acting as defendants have herein.
AS AND FOR A FOURTH CAUSE OF ACTION FO__R NEGLIGENCE

AS TO DEFENDANT CHASE FINLAY
the same force and effect as if hereaRer set forth at length.
52. At all times herein mentioned, defendant CHASE FINLAY had a duty to Ms.
Waterbury, given their romantic and intimate relationship and as to to not taking,
sending, sharing and disseminating sexual, explicit and intimate images of Ms.
Waterbury and other female Ballet dancers, students and others, without their
34 of 59
consent, and sharing it with other male Ballet dancers and others affiliated with New
York City Ballet and breached that duty by his conduct by taking, sending, sharing
and disseminating sexual, explicit and intimate images of Ms. Waterbury and other
female Ballet dancers, students and others, without their consent.
she was without clothing and/or while the two were engaged in sexual activity.
CHASE FINLAY in degrading, demeaning, sexual assaulting, abusing and battering
women, including but not limited to the taking, sending, sharing

and disseminating
sexual, explicit and intimate images of Ms. Waterbury and other female Ballet
dancers, students and others, all without any fault or lack of care on the part of
plaintiff ALEXANDRA WATERBURY.
155. By reason of the foregoing carelessness and negligence of the defendant CHASE
FINLAY, plaintiff ALEXANDRA WATERBURY sustained serious and severe
psychological and emotional distress, mental anguish, embarrassment, and
humiliation, and upon infonnation and belief these injuries are of a pennanent and
lasting nature; that said plaintiff was confined to her bed, home, and/or various
medical institutions as a result thereof, and was incapacitated from attending her
regular activities; and there was caused to be expended sums of money for medical
and hospital care on her behalf.
35 of 59
to compensatory damages from defendant CHASE FINLAY, in such sums as a jury
would find fair, just, and adequate, and plaintiff, ALEXANDRA WATERBURY, is
entitled to punitive damages from defendant CHASE FINLAY, in such sums as a
jury would find fair, just, and adequate, to deter others from similarly acting as
defendants have herein.
AS AND FOR A FIFTH CAUSE OF ACTION FOR NEGLIGENCE

AS TO DEFENDANT AMAR RAMASAR AND ZACHARY CATAZARO
.60. At all times herein mentioned, defendant AMAR RAMASAR and ZACHARY
CATAZARO had a duty to Ms. Waterbury, other female Ballet dancers, students and
other women to not condone, encourage and/or incite the male Ballet dancers,
including Mr. Finlay to degrade, demean, sexual assault, abuse and batter women,
including but not limited to the taking, sending, sharing and disseminating sexual,
explicit and intimate images of Ms. Waterbury and other female Ballet dancers,
students and others, and breached that duty by his conduct which condoned,
encouraged and/or incited male Ballet dancers to degrade, demean, sexual assault,
abuse and batter women, including but not limited to the taking, sending, sharing and
36 of 59
disseminating sexual, explicit and intimate images of Ms. Waterbury and other
female Ballet dancers, students and others.
she was without clothing

and/or while the two were engaged in sexual activity to
AMAR RAMASAR who encouraged, condoned, incited and instigated Mr. Finlay to
share these images with him.
62. Said occurrences were due to the carelessness and negligence of the defendants
AMAR RAMASAR and ZACHARY CATAZARO in condoning, encouraging,
instigating and inciting male Ballet dancers to degrade, demean, sexual assault, abuse
and batter women, including but not limited to the taking, sending, sharing and
disseminating sexual, explicit and intimate images of Ms. Waterbury and other
female Ballet dancers, students and others, all without any fault or lack of care on the
part of plaintiff ALEXANDRA WATERBURY.
63.
By reason of the foregoing carelessness and negligence of the defendants AMAR
RAMASAR and ZACHARY CATAZARO, plaintiff ALEXANDRA
WATERBURY sustained serious and severe psychological and emotional distress,
mental anguish, embarrassment, and humiliation, and upon information and belief
these injuries are of a permanent and lasting nature; that said plaintiff was confined to
her bed, home, and/or various medical institutions as a result thereof, and was
37 of 59
incapacitated from attending her regular activities; and there was caused to be
expended sums of money for medical and hospital care on her behalf.
to compensatory damages from defendants AMAR RAMASAR and ZACHARY
CATAZARO, in such sums as a jury would find fair, just, and adequate, and
plaintiff, ALEXANDRA WATERBURY, is entitled to punitive damages from
defendants AMAR RAMASAR and ZACHARY CATAZARO, in such sums as a
jury would find fair, just, and adequate, to deter others from similarly acting as
defendants have herein.
AS AND FOR A SIXTH CAUSE OF ACTION FOR

ASSAULT AS TO DEFENDANT CHASE FINLAY
67. Plaintiff repeats reiterates, and reallages each and every allegation contained in
those paragraphs of the Complaint marked and designated 1. through 156., inclusive,
with the same force and effect as if hereafter set forth at length.
68. During the time that the defendant NEW YORK CITY BALLET, INC., and/or
its agents, servants, employees, donor, junior board member, principals and/or others
allowed defendant CHASE FINLAY and others in similarly situated positions to
take advantage of those such as plaintiff ALEXANDRA WATERBURY, when she
was clear in her repeated and unequivocal rejections of defendant CHASE
FINLAY's attempts to take images of her and to film their sexual contacts.
38 of 59
69. Defendant CHASE FINLAY's graphic, forced, and unlawful behavior amounted
to a series of events that created a reasonable apprehension in plaintiff and of
immediate, harmful or offensive contact to plaintiff's person, all of which were done
intentionally by defendant to plaintiff without plaintiff's consent.
70. As a direct and proximate result of the aforementioned batteries, plaintiff has
sustained in the past, and will continue to sustain in the future, serious and severe
humiliation.
incurred medical expenses and other economic damages, and will be obligated to
expend sums of money for further medical care and attention in an effort to alleviate
her serious and severe psychological and emotional distress, mental anguish,
embarrassment, and humiliation.
72. Ms. Waterbury was and will be unable for some time to come, to pursue her
usual activities and employment, all due to the serious and severe psychological and
emotional distress, mental anguish, embarrassment, and humiliation she sustained due
to the aforementioned batteries.
73. By reason of the foregoing, plaintiff ALEXANDRA WATERBURY is entitled
to compensatory damages from defendants and/or their agents, servants, employees,
donors, principals and/or others in such sums as a jury would find fair, just, and
adequate, and plaintiff ALEXANDRA WATERBURY is further entitled to punitive
and exemplary damages from defendants and/or their agents, servants, employees,
39 of 59
appropriate to deter said defendant and others from future similar conduct.
74. The amount of damages sought exceeds the jurisdiction of all lower courts that
75. This action falls with exceptions to Article 16 of the C.P.L.R.
AS AND FOR A SEVENTH CAUSE OF ACTION FOR

BATTERY AS TO DEF_ENDANT CHASE FINLAY
77. Throughout their relationship, plaintiff ALEXANDRA WATERBURY was clear
in her repeated and unequivocal rejections of defendant CHASE FINLAY's attempts
to take images of her and to film their sexual contacts.
78. Despite these rejections, defendant CHASE FINLAY still took videos and
photographs of the contacts without plaintiff ALEXANDRA WATERBURY's
consent, and shared these images of plaintiff with others without her consent.
79. Had plaintiff ALEXANDRA WATERBURY known she was being recorded,
she would not have consented to the sexual activity, contact, and/or touching
referenced herein.
80. As such, this graphic, forced, and unlawful behavior amounted to a series of
harmful and offensive contacts to plaintiff s person all of which were done
sustained in the past and will continue to sustain in the future, serious and severe
40 of 59
humiliation.
83. Ms. Waterbury was and will be unable for some time to come, to pursue her usual
activities and employment, all due to the serious and severe psychological and
84. Upon information and belief these injuries are of a pennanent and lasting nature,
plaintiff ALEXANDRA WATERBURY was incapacitated from attending her
regular activities and was caused to expend sums of money for medical care on her
behalf.
85.
By reason of the foregoing, plaintiff ALEXANDRA WATERBURY is entitled
41 of 59
87. This action falls with exceptions to Article I6 of the C.P.L.R.
AS AND FOR A EIGHTH CAUSE OF ACTION FOR ASSAULT AS TO

DEFENDANT NEW YORK CITY BALLET, INC.
89. During the time that the defendant NEW YORK CITY BALLET, INC., and/or
its agents, servants, employees, donor, junior board member,, principals and/or others
allowed defendant CHASE FINLAY and others affiliated with it in similarly situated
positions to take advantage of those such as plaintiff ALEXANDRA
WATERBURY, when she was clear in her repeated and unequivocal rejections of
defendant CHASE FINLAY's attempts to take images of her and to film their sexual
contacts.
90. Defendant NEW YORK CITY BALLET, INC. turned a blind-eye to the
graphic, forced, and unlawful behavior of its agents, servants, employees, donors,
principals and/or others amounted to a series of events that created a reasonable
apprehension in plaintiff and of immediate, harmful or offensive contact to plaintiff s
person, all of which were done intentionally by defendant to plaintiff without
plaintiff s consent.
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humiliation.
93. Ms. Waterbury was and will be unable for some time to come, to pursue her
usual activities and employment, all due to the serious and severe psychological and
94. Defendant NEW YORK CITY BALLET, INC. its agents, servants, employees,
donors, principals and/or others had actual notice that this type of illicit behavior was
going on amongst its employees, yet rather than

stop it from continuing, said
defendants ultimately aided and abetted this type of behavior by directing,
encouraging, and/or facilitating the aforementioned battery that caused the hannful
and offensive contact to plaintiff, and that caused her the injuries herein.
95. As such, defendant NEW YORK CITY BALLET, INC., its agents, servants,
employees, donors, principals and/or others not only encouraged said battery to take
place, but their encouragement, condoning, endorsing, inciting and instigating was a
substantial factor in causing the battery.
43 of 59
donor, junior board member, principals and/or others in such sums as a jury would
find fair, just, and adequate, and plaintiff ALEXANDRA WATERBURY is further
entitled to punitive and exemplary damages from defendants and/or their agents,
servants, employees, donors, principals and/or others in such sums as a jury would
find fair, just, and appropriate to deter said defendant and others from future similar
conduct.
1 97. The amount of damages sought exceeds the jurisdiction of all lower courts that
] 98. This action falls with exceptions to Article I6 of the C.P.L.R.
AS AND FOR A NINTH CAUSE OF ACTION FOR BATTERY AS TO

DEFENDANT NEW YORK CITY BALLET. INC.
1 99. Plaintiff repeats reiterates, and reallages each and every allegation contained in
those paragraphs of the Complaint marked and designated 1. through I88., inclusive,
; 00. Throughout their relationship, plaintiff ALEXANDRA WATERBURY was clear
in her repeated and unequivocal rejections of defendant CHASE FINLAY's attempts
to film their sexual contacts.
01. Despite these rejections, defendant CHASE FINLAY still took videos and
photographs of the contacts without plaintiff ALEXANDRA WATERBURY's
consent.
02. Had plaintiff ALEXANDRA WATERBURY known she was being recorded,
she would not have consented to the sexual activity, contact, and/or touching
referenced herein.
44 of 59
03. As such, this graphic, forced, and unlawful behavior amounted to a series of
hannful and offensive contacts to plaintiff's person all of which were done
!04. As a direct and proximate result of the aforementioned batteries, plaintiff has
sustained in the past and will continue to sustain in the future, serious and severe
humiliation.
06. Ms. Waterbury was and will be unable for some time to come, to pursue her usual
activities and employment, all due to the serious and severe psychological and
07. Upon information and belief these injuries are of a pennanent and lasting nature,
plaintiff ALEXANDRA WATERBURY was incapacitated from attending

her
regular activities and was caused to expend sums of money for medical care on her
behalf.
08. Furthermore, defendant NEW YORK CITY BALLET, INC. its agents, servants,
employees, donors, principals and/or others had actual notice that this type of illicit
behavior was going on amongst its employees, yet rather than stop it from continuing,
45 of 59
said defendants ultimately aided and abetted this type of behavior by directing,
encouraging, and/or facilitating the aforementioned battery that caused the harmful
and offensive contact to plaintiff, and that caused her the injuries herein.
09. As such, defendant NEW YORK CITY BALLET, INC., its agents, servants,
employees, donors, principals and/or others not only encouraged said battery to take
place, but their encouragement was a substantial factor in causing the battery.
AS AND FOR A TENTH CAUSE OF ACTION FOR VIOLATION OF

NEW YORK CITY ADMINISTRATIVE CODE 10-177 AS
TO DEFENDANT CHASE FINLAY
14. Defendant CHASE FINLAY's conduct in this matter is governed by New York
Administrative Code - Unlawful Disclosure of an Intimate

City 10-177*3(b)(1)
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Image, which states that it is illegal to "disclos[e] an intimate image, without the
depicted individual's consent, with the intent to cause economic, physical or
substantial emotional harm to such depicted individual, where such depicted
individual is or would be identifiable to another individual either from the intimate
disclosed."
image or from the circumstances under which such image is
I5. Defendant CHASE FINLAY did in fact disclose (i.e. disseminate/publish)
intimate images (i.e. photographs or films depicting an individual in a manner in
which the depicted individual intended it would not be disclosed) of plaintiff/depicted
individual's intimate body parts (i.e. genitals, pubic area or anus of any person, or the
female nipple or areola of a person who is 1 I years old or older) to other Ballet
principals.
16. These disclosed of images of intimate nature clearly reflected the people
contained therein and made their identifications ascertainable.
17. Further, defendant CHASE FINLAY intended to embarrass, humiliate and cause
emotional and economic harm to Ms. Waterbury.
psychological and emotional distress, mental anguish, embarrassment and
humiliation.
47 of 59
::20. By reason of the foregoing, plaintiff ALEXANDRA WATERBURY is entitled
AS AND FOR AN ELEVENTH CAUSE OF ACTION FOR VIOLATION

O.F
NEW YORK CITY ADMINISTRATIVE CODE 10-177 AS TO
DEFENDANT N_EW YORK CITY BALLET, INC.
24. Defendant NEW YORK CITY BALLET, INC. and/or its agents, servants,
employees, donors, principals and/or others conduct in this matter is governed by
New York Administrative Code - Unlawful Disclosure of an

City 10-177*3(b)(1)
Intimate Image, which states that it is illegal to "disclos[e] an intimate image,
without the depicted individual's consent, with the intent to cause economic, physical
or substantial emotional harm to such depicted individual, where such depicted
48 of 59
individual is or would be identifiable to another individual either from the intimate
disclosed."
image or from the circumstances under which such image is
25. Defendant NEW YORK CITY BALLET, INC. and/or its agents, servants,
employees, donors, principals and/or others did in fact disclose (i.e.
disseminate/publish) intimate images (i.e. photographs or films depicting an
individual in a manner in which the depicted individual intended it would not be
disclosed) of plaintiff/depicted individual's intimate body parts (i.e. genitals, pubic
area or anus of any person, or the female nipple or areola of a person who is 11 years
old or older) to other Ballet principals.
26. These disclosed of images of intimate nature clearly reflected the people
contained therein and made their identifications ascertainable.
27. Further, defendant NEW YORK CITY BALLET, INC. and/or its agents,
servants, employees, donors, principals and/or others intended to embarrass,
humiliate and cause emotional and economic harm to Ms. Waterbury.
psychological and emotional distress, mental anguish, embarrassment and
humiliation.
49 of 59
AS AND FOR A TWELFTH CAUSE OF ACTION FOR AIDING AND

ABETTING
NEW YORK CITY ADMINISTRATIVE CODE 10-177AS TO
DEFENDANT NEW YORK CITY BALLET, INC
33. Plaintiff repeats, reiterates, and realleges each and every allegation contained in
those paragraphs of this complaint marked and designated 1. through 222., inclusive
with the same force and effect as if hereaRer set forth at length.
34. Defendant NEW YORK CITY BALLET, INC. encouraged, permitted,
condoned and created a demeanor, state-of-mind, environment and/or mentality
where its male Ballet dancers degraded, demeaned, mistreated, assaulted, battered
and/or abused women.
35. As a result and consequence of the actions and/or omissions of defendant NEW
YORK CITY BALLET, INC., defendant CHASE FINLAY disseminated intimate,
explicit, and sexual pictures of Ms. Waterbury without her consent.
50 of 59
::36. Defendant NEW YORK CITY BALLET, INC. aided and abetted the violation
of New York City Administrative Code 10-177 on plaintiff ALEXANDRA
WATERBURY by defendant CHASE FINLAY causing damage to plaintiff.
::37. Defendant NEW YORK CITY BALLET, INC. provided substantial assistance
in defendant CHASE FINLAY's violation of New York City Administrative Code
10-177*3.
39. This action falls within the exceptions to Article I6 of the C.P.L.R.
AS AND FOR A THIRTIENTH CAUSE OF ACTION FOR NEGLIGENT

INFLICTION OF EMOTIONAL DISTRESS AS TO DEFENDANTS
NEW YORK CITY BALLET, INC. AND CHASE FINLAY
::40. Plaintiff repeats reiterates, and reallages each and every allegation contained in
41. Defendant NEW YORK CITY BALLET, INC. knew, or should have known,
that their negligence in failing to exercise due care in hiring, training, retaining and
supervising defendant CHASE FINLAY and/or their other agents, servants,
employees, donors, principals and/or others who were engaged in the aforementioned
outrageous conduct towards plaintiff, ALEXANDRA WATERBURY, would create
the probability that she would be caused to suffer severe emotional distress.
42. As a proximate result of the aforementioned assaults, batteries, and other
violations committed against Plaintiff, she has suffered and continues to suffer
51 of 59
extreme mental distress, humiliation, anguish, and emotional and physical injuries, as
well as economic losses, all her damage in amounts to be proven at trial.
::43. Defendant NEW YORK CITY BALLET, INC. committed the acts alleged
herein maliciously, fraudulently, and oppressively with the wrongful intention of
injuring plaintiff ALEXANDRA WATERBURY, from an improper and evil motive
amounting to malice and in conscious disregard of plaintiff's rights, entitling plaintiff
to recover punitive damages in amounts to be proven at trial.
45. This action falls within the exceptions to Article 16 of the C.P.L.R.
AS AND FOR AN FOURTEENTH CAUSE OF ACTION FOR

INTENTIONAL
R[_FLICTION OF EMOTIONAL DISTRESS AS TO DEFENDANTS
NEW YORK CITY BALLET, INC. AND CHASE FINLAY
47. Defendant CHASE FINLAY engaged in outrageous conduct towards plaintiff,
ALEXANDRA WATERBURY, with the intention to cause, or with reckless
disregard for the probability of causing, plaintiff to suffer severe emotional distress.
48. As a proximate result of the aforementioned assaults, batteries, and other
violations committed against Plaintiff, she has suffered and continues to suffer
extreme mental distress, humiliation, anguish, and emotional and physical injuries, as
well as economic losses, all her damage in amounts to be proven at trial.
52 of 59
::49. Defendant CHASE FINLAY committed the acts alleged herein maliciously,
fraudulently, and oppressively with the wrongful intention of injuring plaintiff
ALEXANDRA WATERBURY, from an improper and evil motive amounting to
malice and in conscious disregard of plaintiff's rights, entitling

plaintiff to recover
punitive damages in amounts to be proven at trial.
AS AND FOR A FIFTEENTH CAUSE OF ACTION FOR AIDING AND

ABETTING ASSAULT AS TO DEFENDANT
NEW YORK CITY BALLET, INC
55. Defendant NEW YORK CITY BALLET, INC. aided and abetted the assault of
plaintiff ALEXANDRA WATERBURY by defendant CHASE FINLAY, causing
damage to plaintiff.
53 of 59
::56. Defendants NEW YORK CITY BALLET, INC. provided substantial assistance
in defendant CHASE FINLAY's assault.
AS AND FOR A SIXTEENTH CAUSE OF ACTION FOR AIDING AND

ABETTING BATTERY AS TO DEFENDANT
NEW YORK CITY BALLET. INC
with the same force and effect as if hereaRer set forth at length.
62. Defendant NEW YORK CITY BALLET, INC. aided and abetted the battery
of
plaintiff ALEXANDRA WATERBURY by defendant CHASE FINLAY causing
damage to plaintiff.
63. Defendant NEW YORK CITY BALLET, INC. provided substantial assistance
in defendant CHASE FINLAY's battery.
54 of 59
65. This action falls within the exceptions to Article I 6 of the C.P.L.R.
AND AS FOR A SEVENTIENTH CAUSE OF ACTION FOR INVASION

OF PRIVACY AS TO DEFENDANT CHASE FINLAY
with the same force and effect as if hereaner set forth at length.
67. Defendant CHASE FINLAY recorded the assaults and batteries he committed
upon plaintiff ALEXANDRA WATERBURY, in which she was explicitly depicted
without her consent and/or knowledge
68. Defendant CHASE FINLAY intentionally, unlawfully, and without plaintiff s
consent, written or otherwise, shared the photos of Ms. Waterbury to all of their close
friends, peers, and others at defendant NEW YORK CITY BALLET, INC.
69. The recordings included the likeness, portrait, and/or picture of plaintiff
ALEXANDRA WATERBURY.
70. The recordings were shared by defendant CHASE FINLAY in New York State.
71. Defendant CHASE FINLAY shared the recordings of plaintiff for advertising,
publicity, monetary, and/or trade purposes.
72. The contents of the aforementioned recordings are

highly offensive to a
reasonable person.
73. The images depicting plaintiff in the recordings are not of any legitimate public
concern.
55 of 59
74. Defendant CHASE FINLAY knowingly and intentionally used plaintiff
ALEXANDRA WATERBURY's likeness, portrait and/or picture in

sharing
the
recordings of her in a conscious disregard for her rights, entitling

her to recover
punitive damages in amounts to be proven at trial.
:.75. The amount of damages sought exceeds the jurisdiction of all lower courts which
AND AS FOR A NINTEENTH CAUSE OF ACTION FOR AIDING AND

ABETTING INVASION OF PRIVACY AS TO DEFENDANT
NEW YORK CITY BALLET. INC
78. Defendant NEW YORK CITY BALLET, INC. recommended, hired,
maintained and assigned, as one of their principal ballet dancers, defendant CHASE
FINLAY who was encouraged and emboldened by NEW YORK CITY BALLET,
INC. to unlawfully photograph and disseminate images of Ms. Waterbury's naked
body and/or engaging in sexual activities.
80. Defendant NEW YORK CITY BALLET, INC. aided and abetted the invasion
of plaintiff ALEXANDRA WATERBURY's privacy by defendant CHASE
FINLAY, causing damage to plaintiff.
56 of 59
81. Defendant NEW YORK CITY BALLET, INC. provided substantial assistance
in defendant CHASE FINLAY's invasion of plaintiff's privacy.
WHEREFORE, plaintiff demands judgement against defendants in such sum as a
jury would find fair, adequate and just containing the following relief:
A. A declaratory judgement that the actions, conduct, and practices of
Defendants complained of herein violated the laws of the State of New
York;
B. An injunction and order permanently restraining Defendants from
engaging in such unlawful conduct;
C. An award of damages in an amount to be detennined at trial, plus
prejudgment interest, to compensate plaintiff for all monetary and/or
economic harm; hann to her personal and professional reputations and loss
of career fulfillment; for all

non-monetary and/or compensatory hann,
including
but not limited to, compensation for mental anguish; all other
monetary and/or non-monetary losses suffered by plaintiff; and that by
reason of the foregoing, plaintiff sustained damages in a sum, pursuant to
C.P.L.R. §3017, which exceeds the jurisdictional limits of all lower courts
and exceeds the minimum necessary for diversity jurisdiction in all
Federal Courts which would otherwise have jurisdiction;
D. An award of punitive damages;
57 of 59
E. An award of costs that plaintiff has incurred in this action, as well
as plaintiff's reasonable attorney's fees to the fullest extent permitted by
law, and;
F. Such other and further relief as this Honorable Court may deem
just and proper.
Dated: New York, New York
September 18, 2018
MERSON LAW, PLLC
Jordan K. Merson
Attorneys for Plaintiff

58th 34th
150 East Street OOr
New York, New York 10155
(212) 603-9100
58 of 59
JUPREME COURT OF THE STATE OF NEW YORK

20UNTY OF NEW YORK
-------------------------X
ALEXANDRA WATERBURY,
Index No.: /18
Plaintiff,
-against -
WEW YORK CITY BALLET, JARED ATTORNEY

INC.,
SCHOOL OF AMERICAN VERIFICATION
ONGHITANO, BALLET,
2HASE FINLAY, AMAR RAMASAR, AND
5ACH CATAZARO,
Defendants.
-------X
JORDAN K. MERSON, an attorney duly admitted to practice in the Courts
of New York State, and an associate of the firm MERSON LAW, PLLC., attorneys
br the plaintiff in the within action hereby affirms under penalty of perjury:
That he has read the within complaint and knows the contents thereof, and that the
ame is true to his own knowledge, except as to the matters therein stated to be alleged
1pon information and belief, and that as to those matters he believes it to be true;
That the sources of his information and knowledge are investigations and records
n the file; and
That the reason this verification is made affirmant and not by the plaintiff is
by
hat the plaintiff is not within the County where the attorney has his office.
)ated: New York, New York
September 18, 2018
JORDAN K. MERSON
59 of 59

NYCB Complaint

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NYCB Complaint

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FILED: NEW YORK COUNTY CLERK 09/18/2018 01:30 PM INDEX NO.

!lUPREME COURT OF THE STATE OF NEW YORK

. ARED LONGHITANO, CHASE FINLAY,

COMPLAINT AND JURY TRIAL DEMANDED

CHOOL OF AMERICAN BALLET ("SAB") and ZACH CATAZARO,

(hereinafter collectively "Defendants") hereby alleges the following:

NATURE OF THE CLAIMS

encouraged, fostered, and permitted an environment where its agents, servants,

to disregard the law and violate the basic rights of women.

2. Indeed, defendant JARED LONGHITANO, a Junior Board Member of defendant

agent of, defendant NEW YORK CITY BALLET, INC.

3. Specifically, plaintiff ALEXANDRA WATERBURY, a ballet dancer at other

defendant SCHOOL OF AMERICAN BALLET, is a victim in the Ballet's

several of the Ballet's male members, including defendant CHASE FINLAY.

ALEXANDRA WATERBURY, when she discovered that Ballet principal,

6. Defendant CHASE FINLAY and/or agents, servants, employees, principals of and/or

videos and images of plaintiff, ALEXANDRA WATERBURY, and other

principals and/or others affiliated with the Ballet.

exclusively at NEW YORK CITY BALLET, INC.

affiliated with it to act unlawfully, disrespectfully and in disregard of the rights of

whenever wanted to do so -- "just make sure it occurs in New York

executives and management.

institutional control and supervision by defendant NEW YORK CITY BALLET,

disrespectful environment towards women was at defendant NEW YORK CITY

woman anywhere is similarly embarrassed, humiliated, mistreated and de-humanized

PARTIES OF THE CASE

twenty-one years old.

and is a domestic not-for-profit corporation, duly organized and existing by virtue of

the law of the State of New York.

20 Lincoln Center Plaza, New York, New York, 10023.

operated, managed and controlled the aforesaid production company.

servant and/or employee of defendant NEW YORK CITY BALLET, INC.

principal at defendant NEW YORK CITY BALLET, INC.

and/or employee of defendant NEW YORK CITY BALLET, INC.

0. At all times herein mentioned, defendant AMAR RAMASAR was employed as a

principal at defendant NEW YORK CITY BALLET, INC.

and/or employee of defendant NEW YORK CITY BALLET, INC.

2. At all times herein mentioned, defendant ZACH CATAZARO was employed as a

principal at defendant NEW YORK CITY BALLET, INC.

and/or employee of defendant NEW YORK CITY BALLET, INC.

4. At all times herein mentioned, defendant SCHOOL OF AMERICAN BALLET was

5. At all times herein mentioned, defendant SCHOOL OF AMERICAN BALLET and

graduation from defendant SCHOOL OF AMERICAN BALLET was required in

order to perform at defendant NEW YORK CITY BALLET, INC.

6. At all times herein mentioned, defendants SCHOOL OF AMERICAN BALLET

ego of one another.

7. At all times herein mentioned, defendant SCHOOL OF AMERICAN BALLET

from this, and clearly

BALLET was in locis parentisto its students, including

principals and/or others of SCHOOL OF AMERICAN BALLET were agents,

servants and employees of defendant SCHOOL OF AMERICAN BALLET.

servants and employees ofdefendant NEW YORK CITY BALLET, INC.

2 0. Plaintiff ALEXANDRA WATERBURY and defendant CHASE FINLAY met at

2. Ms. Waterbury, as a student at defendant NEW YORK CITY BALLET, INC.

acceptance, condoning, encouraging, facilitating, inciting and instigating its older

and/or SCHOOL OF AMERICAN BALLET.

with female ballet students.

training, supervision or safeguards to protect these female ballet students despite

7. Indeed, there is a video produced and disseminated by Defendant NEW YORK

CITY BALLET with defendants CHASE FINLAY and AMAR RAMASAR,

FACTS OF THIS CASE

tickets and was profitable.

employees and principals acted unlawfully, recklessly or in otherwise offensive and