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Source material

Public documents

Read the filed allegations directly and consult the official docket for the complete and current procedural record.

Verified Complaint

Web-redacted courtesy copy

This 40-page web copy includes a cover notice and the 39-page Verified Complaint originally filed in Oneida County Supreme Court on March 18, 2026. Personal contact information, signatures, notary credentials, and the name of a separate non-party business have been redacted for privacy and site-presentation purposes.

The official court filing controls. The redactions do not convert allegations into findings and should not be treated as a substitute for the docket copy.

Reading guide

Where topics appear in the complaint

  • Nature of the case and parties: ¶¶ 1-26
  • Relationship, production, and income: ¶¶ 27-47
  • Training and compliance practices: ¶¶ 57-82
  • Prior knowledge, approvals, and contract-copy dispute: ¶¶ 83-103
  • Employer enrollment and separate-program allegations: ¶¶ 104-161
  • Terminations and compensation events: ¶¶ 162-235
  • Damages allegations: ¶¶ 236-273
  • Claims and requested relief: ¶¶ 274-327

Do not publish sensitive or restricted material

Do not post private customer or employee information, policy or medical records, confidential discovery, settlement communications, privileged material, personal recordings not cleared for publication, or anything governed by a protective order. People who may possess relevant evidence should preserve it and seek independent legal advice rather than posting it publicly.