The Legal Aid Society’s 143rd Anniversary Serving New Yorkers

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Today, The Legal Aid Society celebrates its 143rd anniversary. Founded in 1876, in the centennial year of American independence to provide free legal assistance to immigrants, a national movement was born here in New York City that spread across this country.   The vision of our founders that equal access to justice should not be denied because of poverty was a tremendous dream that we and our counterparts throughout the country  work every day to make a reality. 

From its early days, The Legal Aid Society has particularly championed the rights of women, fighting for immigrant working women who needed the protection of the law with wage and dismissal claims. Today, our clients include survivors of domestic abuse, undocumented women seeking a living wage, homeless women trying to secure a safe place for their children to sleep, trans women fighting for health care and women held at Rikers away from their families and communities simply because they cannot afford bail. We are the change for women in New York City, but we do not lose sight of the plight of women throughout the world. We stand in solidarity with those celebrating International Women’s Day throughout the world and the extraordinary and transcendent contributions of women.

The words of the Honorable Learned Hand, Chief Judge of the U.S. Court of Appeals for the Second Circuit, spoken at the 75th anniversary celebration of The Legal Aid Society in 1951, were never truer than they are today: ‘If we are to keep our democracy, there must be one commandment: Thou Shalt Not Ration Justice.’ Today, in the face of new challenges confronting our clients, we stand with them, every day in every borough, fighting for justice.”

The Legal Aid Society Statement on International Women’s Day

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The Legal Aid Society released the following statement today for International Women’s Day.

“On this International Women’s Day, The Legal Aid Society stands in solidarity with women across the nation and globally. We are proud to join in the commemoration and celebration of women and their vital contributions to our organization, our communities, and our city. For over 140 years, women have played a key role in The Legal Aid Society, helping shape both the history of our organization and the legal landscape of our city. Today, our organization serves as a beacon of hope for women across our city, helping women of all backgrounds with the challenges they face.

We tenaciously advocate for our clients, many of whom are women, trans women, and gender non-conforming people from communities of color, who have struggled with poverty and who live under multifaceted layers of oppression. Now, while we take the time to celebrate the incredible achievements of women for women, we must also strengthen our resolve to stand against the systems that perpetuate gender inequality, sexism, transphobia, misogynoir, and all forms of oppression that women face every day.”

 

Legal Aid Caseload Analysis: 88% of Clients Arrested, Prosecuted for Gravity Knife Possession Are New Yorkers of Color

The Legal Aid Society today released a report on analyzed caseload data for gravity knife arrests and prosecutions between January 1, 2018 and June 28, 2018. The analysis reveals that the New York City Police Department and local district attorneys continue to overwhelmingly target New Yorkers of color for gravity knife possession.

These knives – commonly regarded as work tools and sold at the majority of retailers across the country – are used by construction laborers, electricians, stagehands, and other workers throughout New York City.

“NYPD and local prosecutors use the gravity knife statute as a trap to make arrest numbers and to force our clients through the system. Folding knives are treated as tools at stores such as Ace Hardware and AutoZone; but they are treated as weapons once they are found in our clients’ Black and Brown hands. It is time for Governor Cuomo to end this trap, and to prevent thousands of arbitrary arrests,” said Martin LaFalce, Staff Attorney with the Manhattan Criminal Defense Practice at The Legal Aid Society.

“The NYPD and city prosecutors continue to exploit the State’s broken gravity knife statute to target New Yorkers of color who use this tool simply for work purposes. It’s shameful, and the disparate treatment must stop,” said Julie Ciccolini, Analyst at The Legal Aid Society and author of the report. “This report demonstrates a real need for Albany to enact reform immediately, as law enforcement shows no sign of changing their ways any time soon.”

KEY FINDINGS

  • There were 885 gravity knife arrests arraigned by Legal Aid in the first 6 months of 2018
  • 88% of people arrested for gravity knife possession are people of color; 85% are Black or Latino
  • 91% of those arrested for gravity knife possession were charged with a misdemeanor, 9% with a felony
  • The 49th and 79th Precincts made the most gravity knife arrests
  • Fewer than 1% of gravity knife cases in the Bronx are charged as felonies, as compared to 42% in Staten Island
  • The Legal Aid Society represents approximately five gravity knife cases a day, or about 1,800 such cases each year

In 2017 after claims from the NYPD and local prosecutors that gravity knives are uniquely dangerous weapons, The Legal Aid Society issued an analysis of 1,800 violent felony cases where weapons were recovered. Those cases show that gravity knives were alleged to have been used in the commission of violent crime in less than one percent of cases. Canes, crutches, glass bottles, baseball bats, and other household items were alleged to have been used in the commission of violent crime at the same rate as, or more frequently than, gravity knives.

New York’s current gravity knife statute has long garnered criticism for being antiquated, overly broad, and exploited by law enforcement to arrest and prosecute unsuspecting workers. In 2016 and 2017, the New York State Legislature overwhelmingly passed legislation to overhaul the law; but Governor Andrew Cuomo issued vetoes in both years.

Legal Aid Launches “CAPSTAT” – a Public Database of Federal Civil Rights Lawsuits, NYPD Disciplinary Summaries and NYPD Payroll Data

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The Legal Aid Society launched “CAPstat” today – a database containing publically available information culled from federal civil rights lawsuits brought against the New York City Police Department (NYPD) for misconduct, alongside the disciplinary summaries BuzzFeed published last year and other public information – all of which is now easily accessible to the public for the first time.

CAPstat was created to show how transparency can improve the public’s collective ability to identify trends in misconduct and to advocate for reform. The database highlights the amount of taxpayer money spent towards settling repeated incidents of police misconduct that the City has failed to properly track and remedy. The database can and should be used by policymakers and by the NYPD to better identify and prevent systemic patterns of police misconduct and to discipline the officers who repeat this misconduct. The database can also be used as a resource for people who have witnessed or who have been harmed by police misconduct, so as to help them decide whether to take legal action.

“CAPstat will help New Yorkers gain a more thorough understanding of lawsuits filed against the NYPD for misconduct and will help the public hold the NYPD accountable for reoccurring patterns of misconduct that the department itself routinely ignores,” said Cynthia Conti-Cook, Staff Attorney with the Special Litigation Unit at The Legal Aid Society's Criminal Practice. “With today’s launch, we join a national movement including fellow defenders, advocates, and community members to shed much needed daylight on police departments and their actions.”

This website was inspired by decades of work on the parts of grassroots movements, journalists, civil rights attorneys, academics, and policy makers who have advocated for learning from litigation data so as to improve policing policies, trainings, early intervention systems, and accountability. The data was collected by Julie Ciccolini for Legal Aid’s Cop Accountability Project (“CAP”). CAP was started at Legal Aid by staff attorney Cynthia Conti-Cook, and was initially intended to serve Legal Aid's Criminal Defense Practice attorneys who must, due to Civil Rights Law 50-a, argue in the dark for disclosure of internally documented police misconduct. To better serve the public’s right to know about police misconduct in a state where it is shrouded with secrecy due to Civil Rights Law 50-a, we expanded our project to bring this information to the public.

The federal lawsuits included in this database were collected daily between January 2015 and June 2018. For each lawsuit, details are available on the locations and time of the underlying indicent, demographics of the victims, types of civil rights violations alleged, charges underlying false arrest cases, any uses of force, and the outcome or settlement amount.

Similarly, all officers named in the 2015-2018 lawsuits can be sorted based on the total settlement amounts associated with lawsuits they’re named in, the total number of lawsuits they were named in during that period, and their salary and overtime. Each officer also has his or her own profile depicting promotion and salary history, any other publicly known misconduct, and other officers who have also been named in lawsuits.

“Two barriers that we face toward real policing reform are a lack of transparency and accountability-- and accountability requires transparency. I believe that the CAPStat database will be a vital tool for the public as well as for the NYPD and advocates to review, to find and address systemic failures. This administration hides behind 50-a to prevent vital transparency, and I thank the Legal Aid Society for providing this tool that can be used for change,” said Council Member Jumaane D. Williams.

“Transparency and accountability around police misconduct are two of the most important issues we face in the fight for criminal justice reform today,” said Council Member Donovan Richards, chair of the City Council’s Committee on Public Safety. “While the toll police misconduct takes on our families and communities weighs the heaviest, it also hits our city’s wallet hard as well and the more information available, the better we all can be at addressing patterns of abuse and neglect. I’d like to thank the Legal Aid Society for all of the hard work that went into the creation of CAPstat and for their dedication to sensible reforms that will benefit the people of New York City.”

"We know from our wrongful conviction cases that making findings of police misconduct prevents wrongful conviction by identifying patterns of misconduct and enhancing the public safety.

Transparency will earn the public's trust and promises to deliver more reliable criminal justice outcomes by enabling documented findings of misconduct to be made public. Work is being done in this area now in Chicago, Philadelphia, Baltimore and more - so why not New York? Unfortunately the Empire State has the unique distinction of having the worst law in the country and our entire system of justice suffers for it,” said Barry Scheck, co-founder of the Innocence Project.

"Lawsuits provide critically important information about incidents of alleged wrongdoing that can be used to identify and address problem officers, units, and practices. Yet, all too often this data is ignored--to the detriment of city officials, taxpayers, and the public at large. CAPstat allows the NYPD and others to identify practices and people that are the subjects of litigation, and then use that data to investigate the underlying causes for those trends. Lawsuit data should not be relied upon without further investigation and assessment--like all data, it has its flaws. But it offers unique insights into police practices that provoke litigation and payouts,” said Joanna C. Schwartz, Vice Dean for Faculty Development and Professor of Law at UCLA School of Law.

Celebrating Black History Month With the Talent of Nia Witherspoon

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Last night, members of the Legal Aid Staff were treated to a special performance from Nia Witherspoon and her new production “Dark Girls’ Chronicles,” an epic journey of Black womanhood expressed through Black music and dance as we celebrated Black History Month.

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 The event was organized by Anne Oredeko, the Supervising attorney of the Racial Justice Unit.

Pro Bono Bulletin | March 2019

Bob Paul

Bob Paul

Volunteer Spotlight: Bob Paul

When Bob Paul was in Law School at NYU, he had a keen interest in criminal law. His course load was heavy on criminal law and he even represented clients from Legal Aid in Manhattan Criminal Court through a clinical program. But upon graduation, he found that he was unable to find a good job in criminal law. He went to work for a firm and spent nearly 40 years practicing law for a variety of employers, including law firms, banks, and the federal government focusing on the regulation of financial markets and derivatives. As his career in financial services was winding down, he looked for opportunities to give back to the community, and discovered the Attorney Emeritus Program (AEP). Through AEP he found a placement with The Legal Aid Society’s Prisoners’ Rights Project (PRP).

His volunteer work focuses on advocating on behalf of people incarcerated in prisons throughout New York State. For his very first case he wrote a letter to the Superintendent of Upstate Correctional Facility requesting medication for a client. Just one week later, the client reported that the medication had been received. This was an impressive outcome considering that similar claims are often denied, and a great victory for the client. He also joined Legal Aid attorneys on a trip to interview potential plaintiffs for a class action lawsuit on behalf of imprisoned people with mental health disorders, which was filed in January. He noted that is gave him the opportunity to see how his “PRP colleagues used the individual experiences of potential plaintiffs to develop large scale impact litigation.”

Asked about the impact his volunteer service has had, he said “Through my work with PRP I feel like I am making at least a small contribution to improving how our individual clients are treated in DOCCS custody. It is rewarding when I have a client transferred to safe housing or treated more respectfully by staff.” He also noted that he enjoyed the camaraderie he has with the PRP staff.

Bob has been able to expand the work the Prisoners’ Rights Project can do through his volunteering. He is a terrific addition to the team.

Legal Aid, Cravath Announce Settlement for Client Who Was Raped and Sexually Abused by Doc Officers on Rikers Island

The Legal Aid Society and Cravath, Swaine & Moore LLP announced a substantial monetary settlement today on behalf of their client, “Jane Doe,” who was repeatedly raped, sexually abused, and sexually harassed by two New York City Department of Correction (DOC) officers while she was a pre-trial detainee on Rikers Island.

This lawsuit was filed in August 2018 against the City of New York and DOC Officers Jose Cosme and Leonard McNeil, in both their individual and official capacities. Cosme pled guilty to a Criminal Sex Act, a felony charge, which required him to register as a sex offender. McNeil is still employed by the DOC.

In 2015, Jane Doe was a detainee awaiting trial at Rikers Island’s Rose M. Singer Center (RMSC.) There, she suffered brutal rape, sexual abuse, and sexual harassment by Cosme after McNeil conspired with Cosme so Cosme could rape her. McNeil separately also raped, sexually abused, and sexually harassed Jane Doe. As a result of Cosme’s and McNeil’s criminal acts, Jane Doe suffers from severe trauma. After Jane Doe reported the rapes, sexual abuse, and sexual harassment, correction staff and inmates retaliated against her. This retaliation included threats to her life and other verbal abuse, as well as denial of the most basic necessities, such as soap.

“No compensation will ever come close to righting the sexual violence our client suffered at the hands of Jose Cosme and Leonard McNeil while at Rikers Island,” said Marlen Bodden and Barbara Hamilton, Staff Attorneys with the Special Litigation Unit at The Legal Aid Society. “This settlement delivers some justice and further underscores the culture of impunity that exists among correctional staff at NYC jails. We hope other people who have suffered similar trauma at Rikers Island or other local jails will speak out and seek justice.”

“No individual should ever be subjected to the abuse and trauma that our client experienced,” said Brittany L. Sukiennik, associate at Cravath, Swaine & Moore LLP. “This settlement is a small measure of justice for an exceptionally strong woman who has experienced unfathomable trauma. We are hopeful that cases like this will persuade the City to take any and all steps necessary to ensure that the constitutional and human rights of individuals in custody are protected and held sacrosanct.”

Plaintiffs Praise SDNY Ruling That Preserves Vital Humanitarian Program

On behalf of their clients, the Legal Aid Society and Latham & Watkins praised a decision rendered today by United States District Judge John Koeltl on litigation brought last June which preserves a vital humanitarian program – Special Immigrant Juvenile Status (SIJS) – utilized by thousands of abused, abandoned, or neglected children in New York State and others nationwide.

The lawsuit, filed as a class action by five young adults who applied for but were denied SIJS by the U.S. Citizenship and Immigration Services’ (USCIS), challenged a 2018 policy change in which USCIS unilaterally reinterpreted the law in a manner that effectively precluded minors between the ages of 18 and up to 21 from qualifying for SIJS.

The agency’s unannounced policy change, which impacted thousands of immigrant youth across the country, was first reported in April 2018. The Plaintiffs are represented by The Legal Aid Society and Latham & Watkins.

“This sweeping decision leaves no doubt that USCIS deliberately violated the rights of the most vulnerable, young immigrants – those who were abused, neglected, or abandoned by their parents,” said Beth Krause, Supervising Attorney in the Immigration Law Unit at The Legal Aid Society. “We are relieved that the federal courts have once again been willing to rein in the arbitrary and capricious policies of the Trump Administration.”

“It is our duty as lawyers to protect those who are most in need. Congress created the Special Immigrant Juvenile Status program in 1990 to protect a particularly vulnerable group – young immigrants who have been abused, neglected or abandoned by a parent. We are pleased with the court decision to uphold the program on a classwide basis,” said Latham & Watkins partner Robert Malionek, who filed the class action with the Legal Aid Society and argued the cross-motions for summary judgment. “Our class, made up of thousands of abused, abandoned, or neglected young immigrants, once again have a path to citizenship.”

Specifically, the lawsuit challenged USCIS’s new position that New York State Family Courts are not “juvenile courts” for young people aged 18 to up to 21, and are therefore not authorized to issue the orders that must support SIJS applications. This policy change ran counter to a decade of practice. Plaintiffs successfully argued that the agency’s new policy violates the federal Administrative Procedures Act (APA) because it contradicts the statute that created SIJS and misinterprets New York law.

SIJS Background

Since 2008, SIJS has served as a legal pathway for unaccompanied minors under the age of 21, who have been abused, abandoned, or neglected by one or both parents, to obtain lawful permanent residency and a pathway to citizenship. However, under the Trump Administration’s policy change, individuals who are over 18, but not yet 21, no longer qualify for SIJS, despite there being no change in the law or regulations related to SIJS. This is a sharp departure from a decade of consistent policy, where SIJS applications filed by young immigrants between 18 to up to 21 years of age who were placed under guardianship by New York Family Courts were consistently, and properly, granted.

For a young person in New York to apply for SIJS, a New York Family Court must first determine that the applicant was abused, abandoned, neglected or subjected to similar maltreatment under New York State law, that the applicant cannot reunite with one or both parents, and that it’s not in the applicant’s best interest to be returned to the applicant’s country of birth. The court must also declare that the applicant is dependent on the court or place the applicant in the custody of a caretaker. This order is then submitted to USCIS as part of the SIJS application.

Without any prior announcement, USCIS narrowed its interpretation of the law starting in 2017, ultimately documenting its new policy in February 2018. The policy change provided that in cases where applicants are over 18, they no longer qualify, incorrectly reasoning that the state court’s authority ends at 18. This new policy had the practical effect of depriving immigrant youth of the opportunity to regularize their immigration status, and caused tremendous uncertainty, anxiety and other harm to children who have, by definition, already suffered emotional trauma. As the US District Court for the Southern District of New York recognized, the agency’s new position had no basis in law.

You can read the decision here: https://static1.squarespace.com/static/59578aade110eba6434f4b72/t/5c8c65894785d34f4980665c/1552704910483/special_immigrant_juvenile_status.pdf

Prisoners’ Rights Project Staff Acknowledged In Recently Published Book

Lawyers for The Prisoners’ Rights Project are acknowledged in a recently published book, Life and Death in Rikers Island, by the former Chief Medical Officer for Correctional Health Services, Dr. Homer Venters:

“Our mission has also benefited from the counsel (and criticism) of groups outside correctional health, namely, a crew of progressive city council members whom I will mention later in the book, advocates like Jennifer Parrish at Urban Justice, and prisoners’ rights lawyers such as Dale Wilker, Sarah Kerr, John Boston, Riley Evans, and Jonathan Chassan [sic: Chasan].”

Statement on Landmark Appellate Decision Limiting the Reach of SORA Residency Restrictions

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The Legal Aid Society applauded a ruling rendered today by the New York State Appellate Division – Third Department, rejecting the New York State Department of Correction and Community Supervision’s (DOCCS) interpretation of the statutory residency restrictions faced by individuals with prior sex offense convictions.

Specifically, the court held that people whose sex offense sentences had already expired were not subject to the law’s harsh mandatory residency restrictions when they were released to parole following a subsequent non-sex offense conviction. The ruling represents the first such limitation imposed by an appellate tribunal on these restrictions since the law’s enactment.

These restrictions have garnered recent criticism - especially in New York City – for making it virtually impossible for individuals to locate compliant addresses.

Elon Harpaz, Staff Attorney with the Criminal Appeals Bureau and Parole Revocation Defense Unit at The Legal Aid Society, argued this case before the Third Department.

“There is no doubt that New York’s SORA laws impair our clients’ ability to rehabilitate themselves and to successfully re-enter society,” said Elon Harpaz, Staff Attorney with the Criminal Appeals Bureau and Parole Revocation Defense Unit at The Legal Aid Society. “This residency restriction only serves to keep people incarcerated longer and then it isolates them from their families once they have finally secured release. We are pleased that the Court’s decision imposes limitations on the statute’s punitive reach.”

Legal Aid, Cravath Announce Settlement for Client Who Was Raped and Sexually Abused by Doc Officers on Rikers Island

The Legal Aid Society and Cravath, Swaine & Moore LLP announced a substantial monetary settlement today on behalf of their client, “Jane Doe,” who was repeatedly raped, sexually abused, and sexually harassed by two New York City Department of Correction (DOC) officers while she was a pre-trial detainee on Rikers Island.

This lawsuit was filed in August 2018 against the City of New York and DOC Officers Jose Cosme and Leonard McNeil, in both their individual and official capacities. Cosme pled guilty to a Criminal Sex Act, a felony charge, which required him to register as a sex offender. McNeil is still employed by the DOC.

In 2015, Jane Doe was a detainee awaiting trial at Rikers Island’s Rose M. Singer Center (RMSC.) There, she suffered brutal rape, sexual abuse, and sexual harassment by Cosme after McNeil conspired with Cosme so Cosme could rape her. McNeil separately also raped, sexually abused, and sexually harassed Jane Doe. As a result of Cosme’s and McNeil’s criminal acts, Jane Doe suffers from severe trauma. After Jane Doe reported the rapes, sexual abuse, and sexual harassment, correction staff and inmates retaliated against her. This retaliation included threats to her life and other verbal abuse, as well as denial of the most basic necessities, such as soap.

“No compensation will ever come close to righting the sexual violence our client suffered at the hands of Jose Cosme and Leonard McNeil while at Rikers Island,” said Marlen Bodden and Barbara Hamilton, Staff Attorneys with the Special Litigation Unit at The Legal Aid Society. “This settlement delivers some justice and further underscores the culture of impunity that exists among correctional staff at NYC jails. We hope other people who have suffered similar trauma at Rikers Island or other local jails will speak out and seek justice.”

“No individual should ever be subjected to the abuse and trauma that our client experienced,” said Brittany L. Sukiennik, associate at Cravath, Swaine & Moore LLP. “This settlement is a small measure of justice for an exceptionally strong woman who has experienced unfathomable trauma. We are hopeful that cases like this will persuade the City to take any and all steps necessary to ensure that the constitutional and human rights of individuals in custody are protected and held sacrosanct.”

Legal Aid, Kasowitz & Thorobird Save Historic Bronx Church, Finalize Settlement That Will Bring 45 Affordable Housing Units to Grand Concourse Neighborhood

The Legal Aid Society and Kasowitz Benson Torres LLP, with the financial support of Thorobird Companies LLC, secured an important settlement for The First Union Baptist Church of the Bronx, a decades-old church located at 2064 Grand Concourse in the Bronx. After protracted litigation and hard-fought negotiations, the Church, which has faced the risk of losing its historic building since 2012, will retain its current location in a settlement that will also provide 45 units of much-needed affordable rental housing in a rapidly gentrifying community.

“This is a perfect example of collaborating to build sustainable communities while at the same time protecting those vital institutions that maintained stability during the turmoil of economic and social unrest. The people in our communities should not be put on the auction block in the name of economic development when property values rise. We can achieve balanced economic development without furthering economic disparities by making opportunities available to everyone,” said Susan Chase, Staff Attorney with the Community Development Project at The Legal Aid Society.

“Kasowitz Benson Torres is extremely gratified to have had the opportunity to help save First Union Baptist Church in a win-win resolution that will return the Church to a sound financial footing and also provide housing to 45 low-income New York residents and their families,” said David J. Abrams, Partner of Kasowitz Benson Torres and Chair of the firm’s Pro Bono Committee.

“Thorobird Companies is thrilled to have played a part in helping the Church remain in its current location. Helping this neighborhood institution by assisting in its strategy of recovery over the past three years, providing the settlement capital and planning the rebuild of the church along with needed affordable housing is true revitalization in this community,” said Thomas Campbell, Managing Member of Thorobird Companies LLC.

In 2012, the Church filed for bankruptcy, and the original mortgagee sold the note. One month before the final payments were due, the Church defaulted on a payment to its mortgagee, which immediately recorded the deed to the Church property that it held as security in lieu of foreclosure.

Facing an imminent shutdown, the Church contacted the Community Development Project of The Legal Aid Society, whose Pro Bono Practice reached out to Kasowitz to represent the Church to challenge the recording of the deed. After extensive discovery and a trial on the merits in 2017, at which Thorobird Companies testified on behalf of the Church, the bankruptcy court ordered title to be restored to First Union Baptist Church. After the U.S. District Court for the Southern District of New York reversed the decision, the parties fully briefed an appeal to the U.S. Court of Appeals for the Second Circuit on an important unsettled issue of New York real property law. Ultimately, Kasowitz and Legal Aid negotiated a highly favorable settlement with the Church’s mortgagee with the help of affordable housing developer Thorobird Companies.

Under the settlement agreement, Thorobird paid off the Church’s debt and received title to the Church property in exchange for agreeing to build affordable rental housing units on the site and for giving a deed back to the Church at the completion of the renovation of a 4,500-square-foot Church space.

“First Union is a community institution that stood firm and provided resources when the Bronx was burning, through drug epidemics and gang violence. We are so grateful for the expert legal advocacy of the Kasowitz team along with Ms. Chase of Legal Aid in negotiating this complex transaction. Now we will be able to continue our legacy of service to the community,” said Reverend Dr. James E. Wilson, Jr., the Church’s Senior Pastor since 1974.
Susan H. Chase, Staff Attorney with Legal Aid’s Community Development Project, serves as co-counsel to the Church.

The Kasowitz team representing the Church includes Partner David J. Abrams and Associate Andrew Elkin, as well as Special Counsel David Szeker and Sara Saylor Ho, who handled the real estate closing and development transactions.