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practices, supervision, and investigations into child abuse and neglect conducted by ACS, as well as the appointment, training, supervision, promotion, and discipline of all ACS personnel.

35. At all relevant times, the officials, supervisors, managers, caseworkers, agents, and employees of ACS were acting under the color of state law in the course and scope of their duties and functions as officials, supervisors, managers, caseworkers, agents, and employees of ACS and otherwise performed and engaged in conduct incidental to the performance of their lawful duties. The officials, supervisors, managers, caseworkers, agents, and employees acted for and on behalf of ACS with the power and authority vested in them as officials, supervisors, managers, caseworkers, agents, and employees of ACS and Defendant City.

36. As the acts or omissions complained of in this Complaint are those of ACS, references herein to Defendant City shall refer specifically to and include the acts or omissions of

ACS.

Case 1:24-cv-01263 Document 1 Filed 02/20/24 Page 9 of 49 PageID #: 9

7

I. ACS SEARCHES FAMILIES’ HOMES DURING NEARLY ALL OF ITS 50,000 INVESTIGATIONS EACH YEAR, WHICH OVERWHELMINGLY CONCLUDE WITHOUT ANY JUDICIAL DETERMINATION OF WRONGDOING

37. ACS caseworkers’ search families’ homes during nearly every one of the more than

50,000 investigations the agency conducts each year.

8

FACTS

As used in this Complaint, “caseworkers” refers to ACS employees who work on, direct, manage, or assist in ACS’s response to reports of child abuse and maltreatment. This includes, but is not limited to, Child Protective Specialists Level I, Child Protective Specialists Level II, Child Protective Supervisors, Child Protective Managers, and other child protective and diagnostic staff.

As used in this Complaint, “investigations” includes both standard investigations and investigations classified as Family Assessment Response (“FAR”), or what ACS calls “CARES.” Most ACS investigations go into the standard track. N.Y.C. ADMIN. FOR CHILD. SERVS., Flash Report: Monthly Indicators January 2024 7 (Jan. 2024), https://www.nyc.gov/assets/acs/pdf/data-analysis/flashReports/2024/01.pdf [hereinafter, Jan. 2024 Monthly Indicators Report]. FAR investigations mirror standard investigations in many respects, including that FAR investigations involve searches where ACS deploys its Coercive

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Regulators have been tough on big financial mergers, though there are nuances in Capital One’s $35.3 billion takeover bid for Discover.Capital One’s $35.3 billion bid for Discover is a bet that the movement to go cashless will continue to grow.Rogelio V. Solis/Associated PressChallenges, and opportunities, for a financial megadealCapital One’s $35.3 billion takeover to buy Discover Financial Services will create a colossus in the fast-growing credit card industry and a more powerful force in the payment networks that underpin the consumer economy.That will almost surely invite tough scrutiny from a Washington that is increasingly skeptical of big financial mergers. But continuing scrutiny of the two biggest payment networks in the U.S., Visa and Mastercard, may complicate the regulatory math.The deal: Capital One agreed to pay 1.0192 of its shares for each share of Discover, a roughly 26 percent premium to Friday’s trading prices. Discover’s shares were up more than 13 percent in premarket trading on Tuesday.If completed, the transaction would become a giant among credit card lenders, with Bloomberg estimating that the combined company would outstrip JPMorgan Chase and Citigroup in U.S. card loan volume. (That could ratchet up examinations over shrinking competition, and what that means for consumers.)Perhaps more important is the potential supercharging of Discover’s payment network, which has long lagged Visa, Mastercard and American Express. The Wall Street Journal reported that Capital One plans to switch some of its credit cards to the Discover network.The contrarian argument: This is good for Visa and Mastercard. The longtime giants of the payment network business have long been criticized for their fees, with Visa being investigated by the Justice Department. Monday’s deal could give them the opportunity to argue that they would face a newer, bigger competitor.We are having trouble retrieving the article content.Please enable JavaScript in your browser settings.Thank you for your patience while we verify access. If you are in Reader mode please exit and log into your Times account, or subscribe for all of The Times.Thank you for your patience while we verify access.Already a subscriber? Log in.Want all of The Times? Subscribe. More

Robert S. Gard senses a novel opportunity.Jump to: Today’s Theme | Tricky CluesTUESDAY PUZZLE — This is Robert S. Gard’s second crossword for The New York Times and his first crack at a theme set. His first grid, published in September 2023, was a themeless Saturday.Given what I would call a successful themed debut, I find Mr. Gard’s choice of revealer almost paradoxical. Did he second-guess his own talent while constructing, and subconsciously lace his self-doubt into the grid? Or is this just my inner 36-Across reading too deeply into things, as usual? Let’s dive in and find out together.Today’s ThemeCracking Mr. Gard’s theme requires nothing more than an appreciation of how one expression — “in different senses” (59A), our revealer winks — might apply to the entries at 17-, 25-, 36- and 49-Across.What do the “Evidence of a day at the beach” (17A) and a “Chocolate confection with a molten core” (25A) have in common? The answer isn’t immediately evident from the clues’ entries: BIKINI TAN, LAVA CAKE. They both involve warmth, at least.This theory gains shape farther down with a “Flight of fancy” (49A) — a WILD IDEA — which cooks in its own way, too. It all comes together, I think, with the “Effect of secondhand pot smoke” (36A), otherwise known as a CONTACT HIGH.We are having trouble retrieving the article content.Please enable JavaScript in your browser settings.Thank you for your patience while we verify access. If you are in Reader mode please exit and log into your Times account, or subscribe for all of The Times.Thank you for your patience while we verify access.Already a subscriber? Log in.Want all of The Times? Subscribe. More

Physicians say the government’s plan to admit more students to medical school ignores the real cause of doctor shortages: harsh conditions and low wages.Hundreds of interns and residents in South Korea walked off the job on Tuesday, disrupting an essential service to protest the government’s plan to address a shortage of doctors by admitting more students to medical school.While South Korea takes pride in its affordable health care system, it has among the fewest physicians per capita in the developed world. Its rapidly aging population underscores the acute need for more doctors, according to the government, especially in rural parts of the country and in areas like emergency medicine.The protesters, who are doctors in training and crucial for keeping hospitals running, say the shortage of doctors is not industrywide but confined to particular specialties, like emergency care. They say the government is ignoring the issues that have made working in those areas unappealing: harsh working conditions and low wages for interns and residents.Surveys have found that in a given week, doctors in training regularly work multiple shifts that last longer than 24 hours, and that many are on the job for more than 80 hours a week.“The medical system has been collapsing for a while,” said Park Dan, the head of the Korean Intern Residents Association, who resigned from his job at the emergency wing of Severance Hospital in Seoul on Monday. “I couldn’t see a future for myself working in emergency for the next five or 10 years.”The current setup of insurance and government payment systems, Mr. Park added, allows physicians only in a few departments, like cosmetic surgery, to make a decent living.We are having trouble retrieving the article content.Please enable JavaScript in your browser settings.Thank you for your patience while we verify access. If you are in Reader mode please exit and log into your Times account, or subscribe for all of The Times.Thank you for your patience while we verify access.Already a subscriber? Log in.Want all of The Times? Subscribe. More

The all-stock deal, which is valued at $35.3 billion, will combine two of the largest credit card companies in the United States.Capital One announced on Monday that it would acquire Discover Financial Services in an all-stock transaction valued at $35.3 billion, a deal that would merge two of the largest credit card companies in the United States.“A space that is already dominated by a relatively small number of megaplayers is about to get a little smaller,” said Matt Schulz, chief credit analyst at LendingTree.Capital One, with $479 billion in assets, is one of the nation’s largest banks, and it issues credit cards on networks run by Visa and Mastercard. Acquiring Discover will give it access to a credit card network of 305 million cardholders, adding to its base of more than 100 million customers. The country’s four major networks are American Express, Mastercard, Visa and Discover, which has far fewer cardholders than its competitors.But consumer advocates pushed back on the possible deal, saying it posed antitrust concerns. “It is very difficult to imagine how federal regulators could allow Capital One to buy Discover given the requirement that mergers benefit the public as well as insiders,” Jesse Van Tol, the chief executive of the National Community Reinvestment Coalition, said in a statement.The acquisition by Capital One will be one of the first tests of regulatory scrutiny on bank deals since the Office of the Comptroller of the Currency said last month that it intended to slow down approvals for mergers and acquisitions.“It’s hard to know which way it would go, but there will certainly be a lot of attention paid to this deal because of the money and magnitude of the companies involved,” said Mr. Schulz.We are having trouble retrieving the article content.Please enable JavaScript in your browser settings.Thank you for your patience while we verify access. If you are in Reader mode please exit and log into your Times account, or subscribe for all of The Times.Thank you for your patience while we verify access.Already a subscriber? Log in.Want all of The Times? Subscribe. More

Reducing access to Al Aqsa, the sacred mosque compound in Jerusalem that has long been a flashpoint for tensions, may set off unrest, some Israelis warned.The Israeli government was locked in debate on Monday on whether to increase restrictions on Muslims’ access to an important mosque compound in Jerusalem during the holy month of Ramadan, leading to predictions of unrest if the limits are enforced.The office of Prime Minister Benjamin Netanyahu said in a statement that a decision had already been reached, without disclosing what it was. But two officials briefed on the deliberations, who spoke on the condition of anonymity in order to discuss a sensitive matter, said a final decision would be made only after the government received recommendations from the security services in the coming days.On Sunday, Israeli cabinet ministers debated whether to bar some members of Israel’s Arab minority from attending prayers at the Aqsa Mosque compound, a site which is sacred to Muslims and Jews alike, during Ramadan, according to the two officials.Israel has long limited access to Al Aqsa for Palestinians from the Israeli-occupied West Bank, and since the start of the war in Gaza, it has imposed extra restrictions on Arab citizens and residents of Israel. Some had hoped those limits would be largely lifted for Ramadan, which is expected to begin around March 10 — but the talk now is of increasing them, instead.Dan Harel, a former deputy chief of staff in the Israeli military, said in a radio interview that such a move would be “unnecessary, foolish and senseless” and might “ignite the entire Muslim world.” One Arab Israeli lawmaker, Waleed Alhwashla, said on social media that it would be “liable to pour unnecessary oil on the fire of violence.”In Muslim tradition, it is from the site of Al Aqsa compound that the Prophet Muhammad ascended to heaven, and tens of thousands of Muslims visit the mosque every day during Ramadan. For Jews, it is revered as the Temple Mount because it was the site of two Jewish temples in antiquity that remain central to Jewish identity.We are having trouble retrieving the article content.Please enable JavaScript in your browser settings.Thank you for your patience while we verify access. If you are in Reader mode please exit and log into your Times account, or subscribe for all of The Times.Thank you for your patience while we verify access.Already a subscriber? Log in.Want all of The Times? Subscribe. More

Martine Moïse, the widow of President Jovenel Moïse, was charged by a Haitian judge with conspiring in his assassination. She was seriously injured in the attack.A Haitian judge has indicted 51 people for their roles in the 2021 assassination of President Jovenel Moïse, including his wife, Martine Moïse, who is accused of being an accomplice, despite being seriously wounded in the attack.A 122-page copy of the indictment by Judge Walther Voltaire that was provided to The New York Times does not accuse her of planning the killing nor does it offer any direct evidence of her involvement.Instead, it says that she and other accomplices gave statements that were contradicted by other witnesses, suggesting that they were complicit in the killing. The indictment also cites one of the main defendants in the case in custody in Haiti, who claimed that Mrs. Moïse was plotting with others to take over the presidency.The accusations echo those contained in a criminal complaint filed by a Haitian prosecutor and submitted to Mr. Voltaire. The official charge against Mrs. Moïse is conspiracy to murder.A lawyer for Mrs. Moïse, Paul Turner, did not immediately respond to a request for comment.But Mr. Turner, who is based in South Florida, had earlier denied the accusations in the criminal complaint.“She was a victim, just like her children that were there, and her husband,” he told The Times. Mr. Turner said his client is in hiding and her current location is unknown to all but a few people.We are having trouble retrieving the article content.Please enable JavaScript in your browser settings.Thank you for your patience while we verify access. If you are in Reader mode please exit and log into your Times account, or subscribe for all of The Times.Thank you for your patience while we verify access.Already a subscriber? Log in.Want all of The Times? Subscribe. More

Rabbi Harlow’s prayer books, including “Siddur Sim Shalom,” became the standards of worship in Conservative synagogues across North America.Rabbi Jules Harlow, a liturgist who brought a poet’s sensibility and a musician’s cadence to the style of prayer in Conservative Judaism for much of the second half of the 20th century, died on Feb. 12. He was 92.His wife, Navah Harlow, said the cause was aspiration pneumonia. She did not say where he died.For a time, Rabbi Harlow’s major works — prayer books for daily, Sabbath, festival and High Holy Days use — became the standards for worship in Conservative synagogues in North America. Several of his books sold well over 100,000 copies each, according to the Rabbinical Assembly, which published them.Conservative Judaism, which occupies a middle ground between the more liberal Reform and the more traditional Orthodox, was the largest movement in American Judaism until Reform surpassed it in the 1990s.Though Hebrew is the language of Jewish prayer, Rabbi Harlow aspired to make the prayer book accessible to those who did not speak the language. He did this through elegant, if not always literal, translations into English that often captured the rhyme and meter of the original texts.At a funeral service for Rabbi Harlow in Manhattan on Feb. 14, Rabbi Ismar Schorsch, the chancellor emeritus of the Jewish Theological Seminary, called him “the resident poet of the Conservative movement.”Jewish liturgy, Rabbi Schorsch noted, is often “burdened with an excess of words.” Rabbi Harlow wrote and translated prayers and excised more than a few.We are having trouble retrieving the article content.Please enable JavaScript in your browser settings.Thank you for your patience while we verify access. If you are in Reader mode please exit and log into your Times account, or subscribe for all of The Times.Thank you for your patience while we verify access.Already a subscriber? Log in.Want all of The Times? Subscribe. More