Luke Ford

Thursday. 9am. A friend IMs me. "Are you coming to Holly's party Saturday? You guys are so right for each other. I can't wait to see you in action."

I email Holly the first sentence of the IM I received. Six hours later, she calls me back. "Of course you can come, darling. It's an annual party. We don't even bother to send out invites. I forgot to tell you."

Saturday night, the rain ends. I call Holly for the zip code of her parents' home.

She's distracted. She obviously has one hundred things on her mind aside from talking to me. But she eventually gives me the zip code and I use Yahoo maps as a complement to her explicit directions from Friday.

I start my drive tailed by two police cars (I check my pocket and realize I've left my wallet at home). Then they drop away. The 45-minute drive is smooth and sweet. I arrive at the home of Holly's parents at 9pm.

I park on the road and walk the third-of-a-mile uphill. A fancy import in front of me spins its wheels madly as it tries to mount the final hill.

As I approach the house, a tractor comes down the hill and though I scrunch to the side into the bushes as much as I can, there's still only a foot between its blade and me. I feel like the driver is toying with me.

I round the corner. The bartender tells me if I want water, it's around the corner.

I retrace my footsteps and find the water cooler. I have a stiff drink of flat water and then sit down in a corner in the livingroom.

"You're the one who told Holly that because I like the Dallas Cowboys, I must be a fag."

Eventually Holly (holding a nearly-empty beer bottle) comes down and welcomes me. She's stoned (she began the day smoking marijuana resin, all that was left in her pipe, it's much stronger than regular grass, and the friend she shared it with is still knocked out twelve hours later with a ringing headache) and drunk and dressed like a hooker. I love that.

Holly: "Today? We smoked some resin. I told her this is all I've got. If you want some, you can smoke some."

What I love even more is to watch her spending the evening exchanging caresses with the dozen or so men at the party that she's fucked.

But this is not to say that she does not make distinctions. It's most important for her to be with her ex-boyfriend and co-worker Chris. She needs to repeatedly hold on to him right in front of me. She needs to repeatedly break away from talking to me to drape herself over him and whisper in his ear. I love that because they were so wonderful when they were a couple. Nary an unkind word or thoughtless action.

If the only pictures I got to see of Holly locked in embrace with ex-boyfriends (ones I repeatedly asked her to take down) were the ones in Holly's house and on her website, that would not be enough. I need to see it repeatedly in my face. That way I get the full effect and I realize how much I mean to her and how clearly she wants to communicate that to me.

During my sum total of 15-minutes with Holly, her mind is elsewhere. There are a hundred things and people at the party more important to her than me. The legs to the fire grill rate about a nine on her 1-10 scale of importance (ten being of premium importance). Getting refills of champagne is a ten for her. I feel that I rate about a two (along with the starving in Africa). The only time I can sustain her attention is when I aim the camera at her (or when she's reviewing her pictures in my viewfinder).

I largely talk to Humphrey about writing. I tell him about rereading my late mother's book Fireside Stories.

I heard Harris demolished on Dennis Prager's radio show (August 16, 2004). It wasn't fair. Prager already knew all of Harris's arguments but poor Sam hadn't thought about Prager's challenges. Sam thought it had done so poorly in the debate, he asked Prager to come back on the show when he was better prepared.

"That's a good question," he says. He admits that many, maybe most, would not be able to do without it.

"They will seek substitute religions," I say, thinking of communism and Nazism which replaced Christianity as leading ideologies in Europe in the 20th Century. Those ideologies, based on hatred of God and religion, slaughtered far more people (over 100 million within 40 years) than all religious wars and persecutions in all of history put together.

"Sam lays out a framework for a secular humanist approach to life," says Humphrey, "but I only skimmed over it."

"That sort of stuff will only appeal to a tiny number of intellectuals," I reply. "It's not a rubric for ordinary people to lead a meaningful and happy life."

He repeatedly introduces me as the "famous internet scourge of the Adult industry." I like that.

Judging by what he's read, Humphrey says he'd describe the tone of my writing as "vitriolic."

I meet Holly's dominatrix ex-boyfriend Zev Berman, the Hollywood director, who comes with publicist Melissa from thePleasureChest.com.

I meet Holly's ex-boyfriend Brian Gage, an author and graphic designer, with his beautiful young wife.

At 11:45pm, I walk around the party until I find Holly by the bar. She's got a full eight-ounce cup of vodka (with a little cranberry juice).

I want to give things one last chance. Why go away mad when you can go away glad?

"Aren't you violating the rule you told me about Friday [she was painfully hungover on a week during which she had resolved not to drink, we went to breakfast]?" I ask. "That you should never have more than two types of alcohol drinks in a night?"

As the crowd counts down the seconds to the new year, Holly and I lean against each other. She pulls out her camera.

She must want a picture of us bringing in the new year. She wants me. She wants to treasure me as I treasure her. She wants a picture of us to place in frames around her home instead of those of the 40 or so men who proceeded me into her.

But I'm wrong. She has no interest in me. She's not taken a picture of me all night. She wants a picture with Chris.

As we enter 2006, I turn to Holly to kiss her for the first time in three weeks, but I only see her back leaping in the air.

Jumping from her seat, Holly hurls herself into Chris's arms and gives him a passionate kiss on the lips.

It's a cold and lonely 15-minute walk through the mud to my car. Midway down, I open up my zipper and take a long leak goodbye.

I look down. I've tracked Holly's mud into my hovel. I vacuum and scrub but I can't get rid of the filth.

Her mud is all over my hovel, all over my shoes and jeans, and all over my life.

With the wisdom of hindsight, I now realize I should've stuck around so that I could've gotten in line and tasted Chris (and her other lovers) on Holly's lips. She did call my home at 12:24pm to say that she wanted to kiss me (along with about 20 other guys I'm sure).

What a glorious sensation it would've been to have tasted those drunken men on her mouth and breathe in their smell on her body.

Until Saturday night, I mainly saw Holly's previous lovers laid out on her refrigerator (and in frames in almost every room of her house, including the bedroom), on her website, and sometimes at parties (or those who just unexpectedly walk into her home when I'm with her, I guess they've been granted that right).

Now I've met a dozen of them in one night and gotten to see her do everything with them short of opening up an orifice and bringing them inside. I love that. I love how it makes me feel. I love dating and sleeping around. It's such a wonderful preparation for a lasting marriage.

Thanks to the miracle of the internet, we can all enjoy the handsome visages of Holly's ex-boyfriends. It makes a man feel so special when he sees daily reminders of his girl's ex-lovers and gets to constantly hear about how much they mean to her (how she's cancelling a snowboarding trip to host a birthday party for a boyfriend from seven years ago).

Though many people break up in anger, that is not true with Holly and I. Though twelve years my junior, she has taught me to not look back in anger, but in love.

Thus, it is with love in my heart that I lay out the following photo gallery that I've been forced to constantly confront since I met Holly, and visited her home and website. She's a special girl to be able to maintain such an intimate connection with so many men.

Some people might read sarcasm into my commentary. They should not. Holly is the sweetest girl. She never did anything bad to me. That I was not more important to her is my problem, not her's. That I have had no appetite since Dec 11 is my problem, not her's. That I am a basketcase right now is my fault, not her's. Holly was only good to me. My problem was that I wanted more than she could give. I was not content with sloppy seconds, with tasting Chris's kiss on her lips. If only I wasn't so homophobic.

Holly had a heart -- how shall I say? -- too soon made glad, too easily impressed; she liked whatever she looked on, and her looks went everywhere. It was all one! My favour at her breast, the dropping of the daylight in the West, a bar tender, a movie director, a journalist, a professor, a dominatrix. Each drew from her alike the approving speech, the blush, the blowjob.

She thanked men, -- good! but thanked somehow -- I know not how -- as if she ranked me with any other man. Who'd stoop to blame this sort of trifling? Even had you skill in speech -- (which I have not) -- to make your will quite clear to such a one, and say, "Just this or that in you disgusts me; here you miss, or there exceed the mark" -- and if she let herself be reproved, there would be some stooping, and I choose never to stoop.

She smiled, no doubt, whenever I with her; but who was with her without much the same smile?

Vilnii writes: "Amalek was wrong! In hindsight, Holly did not invite you over to her party to introduce you to her parents. You were invited because she wanted to make a point, and it appears she made sure you got the message. The good news is that what you feel now (well-written by the way) is as bad as it gets. In men, the emotions and hurt typically wear off quickly from here on."

Fritz writes: "Sorry about your heartbreak, Luke. In the end, though, you did get a wonderful story out of it."

"The worst of human atrocities," if we are to count by numbers or murders, were committed by aggressively anti-religious ideologies such as Nazism and Communism, which murdered about 100 million people over 40 years. All religious wars and persecutions in all of history have not killed that many.

If you don't think porn is addicting, then you are living in a dreamworld (not that porn being addicting necessarily argues that porn is bad as everything that gives pleasure, including religion, is addicting). Millions of men in the United States are addicted to porn and for one who is, it is a disabling and shaming addiction.

How would I define porn addiction? Unless you are looking at porn for work, spending more than an hour a day with it on average is a good indication of addiction. Porn's primary purpose is solitary masturbation. However you feel about wanking, it's hard to argue that it is ennobling.

What people do in the privacy of their own homes has been an obsessive concern of at least as many non-Christian societies as Christian ones. For instance, every society has developed taboos about sex even when that sex is conducted in the privacy of one's home. There aren't many societies where incest and bestiality are OK, for instance, even when it is done in the privacy of one's home.

If Hitler was Christian, why didn't he take on a Christian symbol? Instead, Nazism took on the swastika, a pagan symbol. For more on this, read Dennis Prager's book Why The Jews? The Reason For Antisemitism:

Daryl writes: "Since, unfortunately, Googling "Tamar Ross" gives prominence to your uncomprehending review of her outstanding work, it is suggested that you remove your references to her & her work. Better still, if you are able to seriously engage her writing & thought, try again. She, to my knowledge, is the first person to attempt a marriage of process philosophy & serious commitment to halacha. In ways perhaps unavailable to you, yet anyway, this is of great moment. It reflects poorly on you to have published such remarks."

That's one of the more interesting conundrums in my in-box today, but first, I want to address my loyal readers who were worried about me, given the intensity of my reaction to recent events in my social life. I'm fine. It's like when you have a bad case of food poisoning after eating something that looked perfectly delicious and might even have tasted wonderful, only the busboy who served it to you failed to wash his hands after defecating, and a few hours later you think life is not worth living. But then it passes, you clean yourself up, and you get on with life.

Now, on to today's most curious question. Nadine from Manhattan Beach writes Luke: "Is it normal to fetishize a car? I recently caught my husband inserting his penis into the exhaust pipe of our SUV. He did not see me, as he was too busy playing with the car, but the fact remains that I saw what I saw, and it has left me extremely upset. He first lubes the pipe with some sort of gel (which he does not use on me), wiggles himself into position, and goes at it while sitting on a low, wheeled cart. I've looked all over the internet for guidance, and I know just about anything can be fetishized, but I've found nothing. Should I be afraid to live with this man?"

The answer to this question must start where all moral inquiries, properly addressed, should start: the Torah. According to the Oral Law of the Rabbinate, that which is not prohibited is allowed. The torah does not forbid a man from inserting his penis into the tail pipe of an automobile or a light truck, provided that none of his seed has been spilled in the process, and provided that he is not needlessly endangering his (or your) health. Before confronting him, I would inspect the tail pipe for tell-tale signs of semen. It is, by the way, always a bad sign when a women discovers that her man is depositing semen in a tail pipe. Provided that is not the case, and he is not endangering his or your health (to develop that query further, one must consult both a urologist and a mechanic), I would let sleeping dogs lie.

Got a question? I've got an answer. Write to Just_ask_Luke@yahoo.com, and watch as your problem is resolved.

Cosmo writes: "That YULA story you're referring to is pretty astounding. Makes me squirm. I think that kind of stuff is unheard of at Beverly Hills High."

'I need to feel fulfilled independently otherwise I will never be whole enough to have a good relationship'

I hear this (mainly from women) a lot and I think it's nonsense (even though it is obviously true you should try to be the best you you can be, even if you are not in a relationship).

A woman's deepest need is to feel worthy of love and a man's is to feel competent.

People need people, people can not be fulfilled without close relationships with others, and that aching hole can not be fulfilled without others. You can not on your own make yourself whole. No individual is whole on his own. It is through our interactions with others (and the relationships that we develop) that we grow. We don't grow on our own (except in solitary hobbies).

During his "Happiness" hour, the second hour of Friday's show, he read an announcement through his tears that he was getting divorced from his second wife Fran (who converted to Orthodox Judaism in 1988 to marry him).

He said he did not regard the marriage as a failure. That they had many good years together and had good kids.

Prager worried if his listeners would take his moral teachings less seriously because of his divorce.

After telling his three kids (one created from his first marriage, one inherited from Fran's first marriage, and one adopted with Fran), Prager said his next priority was to tell his listeners about his divorce.

In 2004, Prager cited personal reasons for not running for the Republican nomination for the U.S. Senate to oppose Democratic incumbent Barbara Boxer.

Prager has always been staunchly opposed to reporting on private lives, including the private lives of public figures. He said it was a consideration that journalists would scrape through his life looking for scandal if he ran for public office.

Fran is a leggy blonde and a former actress. Dennis has often said he couldn't speak so openly about such intimate topics as sex if he was not blessed with such a wonderful marriage.

Luke says: All these rabbis are charedi (ultra-Orthodox) and are natural opponents of innovative Modern Orthodox rabbis such as Mordecai Tendler. So many people are going to view the above statement as political rather than moral.

The Tendlers are a powerful family. It's like going up against the Corleones, to use an example from the Godfather movies.

Supreme Court of the State of New York County of New York
Filed: December 20, 2005
Index No: 05117629
Plaintiff designates New York County as the place of trial
Summons
The basis of venue is plaintiff's residence
Plaintiff resides at:
(Address removed)
County of New York

Survivors Name Removed, Plaintiff,
-against-
Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, and
Mordecai Tendler, Defendant

To the above named Defendants:
You are hearby summoned to answer the compliant in this action and to serve a copy of our answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive of the day of service for within 30 days after the service is complete in this summons is not personally delivered to you within the State of New York); and in case of failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint.

Dated: New York, New York
December 20, 2005

Yours, etc., Kramer and Dunleavy, LLP
Attorneys for Plaintiff

Lenore Kramer, Esq.
A Member of the Firm
350 Braodway, Suite 1100
New York, New York 10013
(212) 226-6662

Defendants Addresses:
Kehillat New Hempstead: The Rav Aron Jofen
720 Union Road
New Hempstead, New York 10977

Mordecai Tendler
653 Union Road
Spring Valley, New York 10977
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Supreme Court of the State of New York County of New York

Verified Complaint
Filed December 20, 2005
Index No: 05117629

Survivors Name Removed, Plaintiff,
-against-
Kehillat New Hempstead: The Rav Aron Jofen Community Synagogue, and
Mordecai Tendler, Defendants.

Plaintiff, by her attorneys, KRAMMER & DUNLEAVY, LLP., complaining of the defendants, respectfully alleges, upon information and belief, as follows:

1. That at all times hereinafter mentioned, defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE, was and still is a domestic not-for-profit corporation duly organized and existing pursuant to the Religious Corporation Law of the State of New York.

2. That at all times hereinafter mentioned, defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE held itself open to members of the public as a place of worship, guidance and sanctuary.

3. Defendant MORDECAI TENDLER was and still is the founder and leader of defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE.
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4. Upon information and belief, defendant MORDECAI TENDLER was and still is an employee of defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE.

5. At all relevant times, defendant MORDECAI TENDLER had a reputation as a scholar, educator and community leader within the Orthodox community.

6. At all relevant times, defendant MORDECAI TENDLER held himself out to the public and to the plaintiff as a counselor and advisor with an expertise in women's issues.

7. That the plaintiff (SURVIVORS NAME REMOVED) first became acquainted with defendant MORDECAI TENDLER and his work on behalf of women in 1994.

8. That beginning in 1994, plaintiff (NAME REMOVED) consulted by telephone with the defendant MORDECAI TENDLER on various personal issues.

9. That beginning in 1995, defendant MORDECAI TENDLER began to actively recruit plaintiff (NAME REMOVED) to join his congregation at defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE.

10. That in September, 1996, plaintiff (NAME REMOVED) began attending services at defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE.
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11. At all relevant times, defendant MORDECAI TENDLER took on the role of counselor and advisor to plaintiff (NAME REMOVED) and did counsel and advise her with respect to her personal, legal and financial problems.

12. At all relevant times, a relationship of confidence and trust existed between the plaintiff (NAME REMOVED) and the defendant MORDECAI TENDLER.

13. At all relevant times, defendant MORDECAI TENDLER represented to plaintiff (NAME REMOVED) that she was his "favorite" and his "closest."

14. At all relevant times, defendant MORDECAI TENDLER represented to plaintiff (NAME REMOVED) that he would "be there" for all of her needs.

15. At all relevant times, defendant MORDECAI TENDLER represented to the plaintiff (NAME REMOVED) that he would assist her in finding a prospective husband so that she would be able to marry and have children, as she wished.

16. At all relevant times, defendant MORDECAI TENDLER represented himself as an advisor, a father figure and a god to plaintiff (NAME REMOVED).

17. Beginning in November, 2001, defendant MORDECAI TENDLER began a sexual relationship with plaintiff (NAMED REMOVED).
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18. That from November 2001 through May, 2005, defendant MORDECAI TENDLER had an ongoing sexual relationship with plaintiff (NAME REMOVED).

19. That prior to and throughout the duration of the aforsaid sexual relationship, defendant MORDECAI TENDLER advised plaintiff (NAME REMOVED)
that she was "close to the possiblity of finding a husband" and that she would never find a husband in her current state.

20. That prior to and throughout the duration of the aforesaid sexual relationship, defendant MORDECAI TENDLER advised plaintiff (NAME REMOVED) to permit him to have sexual intercourse with her so that her "life would open up and men would come" to her.

21. That prior to and throughout the duration of the afordsaid sexual relationship, defendant MORDECAI TENDLER advised plaintiff (NAME REMOVED) that "Everything was closed" to her and that she should let him "open up her to the world."

22. At all relevant times, defendant "MORDECAI TENDLER advised plaintiff (NAME REMOVED) that, if she had sexual intercourse with him, "doors would open," she would be "open up to meeting men" and she "would get married and have children."

23. That from November 2001 through May, 2005, defendant MORDECAI TENDLER had sexual relations with plaintiff (NAME REMOVED) at
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various locations, including in his rabbinical study at defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE.

24. At all relevant times, defendant MORDECAI TENDLER told plaintiff (NAME REMOVED) that he "was as close to God as anyone could get."

25. At all relevant times, defendant MORDECAI TENDLER told plaintiff (NAME REMOVED) that he "talks to God all the time."

26. At all relevant times, defendant "MORDECAI TENDLER told plaintiff (NAME REMOVED) that he "was the Messiah."

27. That plaintiff (NAME REMOVED) was induced to engage in this physical relationship with defendant MORDECAI TENDLER as part of a course of sexual therapy which he represented would lead to her achieving her goals of marriage and children.

28. At all relevant times, defendant (MORDECAI TENDLER warned plaintiff (NAME REMOVED) that, if she told anyone about the sexual therapy, he "would have her placed in a straight jacket," "have her put in the penitentiary" and/or "have her thrown in jail."

29. At all relevant times, defendant "MORDECAI TENDLER warned plaintiff (NAME REMOVED) that, if she told anyone about the sexual therapy, he "would have her banned from the shul (synagogue)" and "would turn the community against her."
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30. At all relevant times, defendant MORDECAI TENDLER advised plaintiff (NAME REMOVED) that engaging in sexual relations with him, was her "only hope" to open her up to become receptive to men.

31. At all relevant times, plaintiff (NAME REMOVED) believed the words, advice and threats of defendant MORDECAI TENDLER.

32. That once plaintiff (NAME REMOVED) submitted to his course of sexual therapy, rather than assisting her to reach her goals of marriage and children, defendant MORDECAI TENDLER physically and emotionally abused plaintiff for his own sexual pleasure and gratification.

AS AND FOR A FIRST CAUSE OF ACTION FOR FRAUD

33. Plaintiff repeats and reiterates each and every allegation contained in paragraphs 1 though 32 inclusive, with the same force and effect as in specifically set forth herein at length.

34. That the aforesaid representations made by defendant MORDECAI TENDLER to plaintiff (NAME REMOVED) were false and reckless.

35. That at the time he made the aforesaid representations, defendant MORDECAI TENDLER knew them to be false and reckless.

36. That defendant MORDECAI TENDLER made the aforesaid representations with the express intent to deceive plaintiff (NAME REMOVED) and induce her into a sexual relationship with him.
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37. That in knowingly making the aforesaid false and reckless representations to plaintiff (NAME REMOVED), defendant MORDECAI TENDLER took unfair advantage of his position as her counselor and advisor.

38. Plaintiff (NAME REMOVED) relied on the false and reckless misrepresentation of defendant MORDECAI TENDLER and engaged in sexual relations with him.

39. That had plaintiff (NAME REMOVED) known that the course of sexual therapy advised by defendant MORDECAI TENDLER was solely for his personal pleasure and gratification, she would not have engaged in sexual relations with him.

40. That as a result of the foregoing, plaintiff (NAME REMOVED) was physically violated, had her reputation impugned, was ostracized from her synagogue and has lost her standing in the community.

41. That as a result of the foregoing, plaintiff (NAME REMOVED) has been injured and damaged in a sum which exceeds the jurisdictional limitations of all the lower Courts that would otherwise have jurisdiction over this action.

AS AND FOR THE SECOND CAUSE OF ACTION FOR BREACH OF FIDUCIARY DUTY

42. Plaintiff repeats and reiterates each and every allegation contained in paragraphs 1 through 41 inclusive, with the same force wand effect as if specifically set forth herein at length.
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43. At all relevant times, defendant MORDECAI TENDLER occupied a position as fiduciary to the plaintiff (NAME REMOVED) as her counselor, advisor and therapist and owed her a relationship of trust and confidence.

44. That as a result of the foregoing, defendant MORDECAI TENDLER breached his fiduciary duty to plaintiff (NAME REMOVED).

45. That as a result of the foregoing, plaintiff (NAME REMOVED) was physically violated, had her reputation impugned, was ostracized from her synagogue and lost her standing in the community.

46. That as a result of the foregoing, plaintiff (NAME REMOVED) was caused to and has suffered and sustained severe and serious personal injuries, severe and serious conscious pain and suffering, severe and serious mental distress and anguish and attendant economic losses.

47. That as a result of the foregoing, plaintiff (NAME REMOVED) has been injured and damaged in a sum which exceeds the jurisdictional limitations of all lower Courts that would other wise have jurisdiction over this action.

AS AND FOR THE THIRD CAUSE OF ACTION FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

48. Plaintiff repeats and reiterates each and every allegation contained in paragraph 1 through 47 inclusive, with the same force and effect as if specifically set forth herein at length.

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49. Defendant MORDECAI TENDLER encouraged his congregates at defendant KEHILLAT NEW HEMPSTEAD: RAV ARON JOFEN COMMUNITY SYNAGOGUE, to harass, threaten and intimidate plaintiff (NAME REMOVED).

50. The congregates at defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE did harass, threaten and intimidate plaintiff (NAME REMOVED).

51. Defendant MORDECAI TENDLER engaged in a concerted scheme to embarrass, humiliate and diminish plaintiff (NAME REMOVED) in the orthodox community so as to injure her reputation and destroy her credibility.

52. Defendant MORDECAI TENDLER knew, or should have known, that his actions towards plaintiff (NAME REMOVED) in falsely inducing her into a sexual relationship, in physically violating and abusing her, in causing her to be harassed, threatened, intimidated and ostracized from the community and in intentionally injuring her reputation and standing in the community would result in serious emotional distress, pain and suffering to her.

53. In doing the actions hereinabove alleged, defendant MORDECAI TENDLER acted with willful, wanton, reckless, intentional and deliberate disregard for the likelihood that plaintiff would suffer severe emotional distress, pain and suffering as a direct and proximate result of his actions.

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54. The aforementioned wrongful conduct of defendant MORDECAI TENDLER was extreme and outrageous and went beyond all bounds of civility and decency.

55. That as a result of the foregoing, plaintiff (NAME REMOVED) was caused to suffer severe mental and emotional distress, pain and suffering.

56. That as a result of the foregoing, plaintiff (NAME REMOVED) has been injured and damaged in a sum which exceeds the jurisdictional limitations of all lower Courts that would otherwise have jurisdiction over this action.

AS AND FOR A FOURTH CAUSE OF ACTION FOR NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

57. Plaintiff repeats and reiterate each and every allegation contained in paragraphs 1 through 56 inclusive, with the same force and effect as if specifically set forth herein at length.

58. At all relevant times, defendant MORDECAI TENDLER was aware that plaintiff (NAME REMOVED) trusted him, relied on him and placed her confidence in him.

58. At all relevant times, defendant MORDECAI TENDLER knew or should have known that his actions would cause her severe mental and emotional distress, pain and suffering.
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59. That as a result of defendant's actions, plaintiff (NAME REMOVED) was caused to suffer severe mental and emotional distress, pain and suffering.

60. That as a result of the foregoing, plaintiff (NAME REMOVED) has been injured and damaged in a sum which exceeds the jurisdictional limitations of all lower Courts that would otherwise have jurisdiction over this action.

AS AND FOR A FIFTH CAUSE OF ACTION FOR NEGLIGENT RETENTION

61. Plaintiff repeats and reiterates each and every allegation contained in paragraphs 1 through 60 inclusive, with the same force and effect as if specifically set forth herein at length.

62. At all relevant times, defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE was aware of the aforesaid conduct and actions of defendant MORDECAI TENDLER.

63. At all relevant times, defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE knew or should have known of propensity of defendant MORDECAI TENDLER for the aforesaid conduct.

64. At all relevant times, defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE knew or should
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have known that defendant MORDECAI TENDLER used his rabbinical study at the synagogue to conduct his sexual therapy sessions with congregation members.

65. At all relevant times, defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE knew of facts that would lead a predent party to investigate the use by defendant MORDECAI TENDLER of his rabbinical study at the synagogue.

66. At all relevant times, defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE had notice of prior allegations of inappropriate sexual conduct by defendant MORDECAI TENDLER.

67. That in spite of the aforesaid notice of prior allegations of inappropriate sexual conduct by defendant MORDECAI TENDLER, defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE took no steps to warn or protect plaintiff and other female congregants, to adequately supervise defendant, to remove defendant from his position of authority or to make an appropriate investigation.

68. That defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE, was grossly negligent as follows: in failing to properly and adequately supervise the activities of defendant MORDECAI TENDLER; in failing to use reasonable care to correct the conduct of defendant MORDECAI TENDLER; in failing to remove defendant MORDECAI TENDLER was an employee; in failing to conduct an adequate and appropriate investigation; in
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failing to warn congregants of in failing to take the steps necessary to have prevented the fraud and assault on plaintiff; and, in further failing to exercise that degree of due care as a reasonable party under the same or similar circumstances.

69. That as a result of the foregoing, plaintiff (NAME REMOVED) was physically violated, had her reputation impugned, was ostracized from her synagogue and lost her standing in the community.

70. That as a result of the foregoing, plaintiff (NAME REMOVED) was caused to and has suffered and sustained severe and serious personal injuries, severe and serious conscious pain and suffering, severe and serious mental distress and anguish and attendant economic losses.

71. That as a result of the foregoing, plaintiff (NAME REMOVED) is entitled to recover punitive damages from and against defendant KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE.

72. That as a result of the foregoing, plaintiff (NAME REMOVED) has been injured and damaged in a sum which exceeds the jurisdictional limitations of all lower Courts that would otherwise have jurisdiction over this action.

WHEREFORE, plaintiff demands judgment against defendants KEHILLAT NEW HEMPSTEAD: THE RAV ARON JOFEN COMMUNITY SYNAGOGUE and MORDECAI TENDLER for both compensatory and punitive damages in the sum which exceeds the jurisdictional limitations of all lower Courts that would.
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otherwise have jurisdiction over this action and is within the jurisdiction of this Court

Dated: New York, New York
December 20, 2005

Yours, etc.,
KRAMER & DUNLEAVY, L.L.P.
By Lenore Kramer
A Member of the Firm
Attorneys for Plaintiff
Office and Post Office Address
350 Broadway - Suite 1100
New York, New York 10013
(212) 226-6662
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VERIFICATION

STATE OF NEW YORK )
:ss
COUNTY OF NEW YORK)

I, the undersigned, an attorney admitted to practice in the Courts of New York State, state that I am a member of the firm of KRAMER & DUNLEAVY, L.L.P. attorneys for the plaintiff in the within action; I have read the foregoing verified complain and know the contents thereof; the same is true to my own knowledge, except as to the matters therein stated to be alleged on information and belief, and as to those matters I believe it to be true. The reason this verification is made by me and not by plaintiff, is because the plaintiff is not now within the County where deponent maintains her offices.

The grounds of my belief as to all matters not stated upon my own knowledge are as follows:

Conversations with plaintiff and a review of the file maintained at my office on this matter.

I affirm that the foregoing statements are true, under the penalties of perjury.

Dated: New York, New York
December 20, 2005

Lenore Kramer