SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS
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NATHAN ROSENBERG, a/k/a NUCHUM ROSENBERG,

Index No:

/ 15

Date Purchased: 9 / 1 / 15
Plaintiffs designate KINGS County as the
place of trial. The basis of venue is
plaintiffs residence

Plaintiff,
-against-

SUMMONS

MEILECH SCHNITZLER,

Plaintiff resides at:

131 Division Ave., Bklyn, NY

Defendant.
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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 plaintiffs 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
Defendants address:
SEE ATTACHED RIDER

RIDER
Defendants addresses:
Meilech Schnitzler
156 South 8th Street, Apt. 31C
Brooklyn, New York 11211

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS
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Index No: ___________ / 15
NATHAN ROSENBERG, a/k/a NUCHUM
ROSENBERG,
VERIFIED COMPLAINT
Plaintiff,
-againstMEILECH SCHNITZLER,
Defendants.
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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.

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 plaintiffs 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 plaintiffs 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 ROSENBERGs 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 plaintiffs eyes.
11.

SCHNITZLERs attack on ROSENBERG was plainly motivated by retribution

for ROSENBERGs 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.

Plaintiffs 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 SCHNITZLERs attack, the plaintiff was caused to become

seriously and permanently injured.

18.

As a result of SCHNITZLERs 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; plaintiffs 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 defendants actions, the plaintiff was caused to suffer severe and

permanent personal injuries, such injuries being set forth above in greater detail.
22.

The defendants 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 attorneys fees to the extent permitted
by law.
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

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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.

Dated: Brooklyn, New York

September 2, 2015

Robert J. Tolchin

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS
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Index No: ___________ / 15
NATHAN ROSENBERG, a/k/a NUCHUM
ROSENBERG,
Plaintiff,
-againstMEILECH SCHNITZLER,
Defendants.
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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 646386-3033 or efile@courts.state.ny.us.

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

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS
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Index No: ___________ / 15
NATHAN ROSENBERG, a/k/a NUCHUM
ROSENBERG,
Plaintiff,
-againstMEILECH SCHNITZLER,
Defendants.
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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: _________________________

THE BERKMAN LAW OFFICE, LLC

111 LIVINGSTON STREET, SUITE 1928
BROOKLYN, NEW YORK 11201
718-855-3627