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UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

______________________________________________________________________________ 

RONALD E. and LESLIE A. CHAMBERS, : 

as GUARDIANS of FERREN CHAMBERS, : 

an incapacitated person and : CIVIL ACTION 

RONALD E. and LESLIE A. CHAMBERS, : 

IN THEIR OWN RIGHT : NO. 

1843 Strahle Street : 

Philadelphia, PA 19152 : 

 PLAINTIFFS : 

: 

v. : 

 : JURY TRIAL DEMANDED 

SCHOOL DISTRICT OF PHILADELPHIA : 

BOARD OF EDUCATION : 

2130 Arch Street, Fifth Floor : 

Philadelphia, PA 19103-1390 : 

 DEFENDANT : 

COMPLAINT

I. JURISDICTION AND VENUE

1. This action arises under 28 U.S.C. §1331, 1343, 1367, as plaintiffs’ claims arise 

under the United States Constitution and statutes including, Rehabilitation Act of 1973, 29 

U.S.C. §504, Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. §1400, et seq. and 

Civil Rights Act, 42 U.S.C. §1983. 

2. Venue for this action is proper in this Court under 28 U.S.C. §1391 as the events 

giving rise to Plaintiffs’ claims occurred within the territorial limits of the United States District 

Court for the Eastern District of Pennsylvania. 

II. PARTIES

3. Plaintiff, Ferren Chambers, is an adult individual and citizen of the 

Commonwealth of Pennsylvania, residing at 1843 Strahle Street, Philadelphia, PA 19152. 

4. Plaintiff, Ronald E. Chambers is an adult individual and citizen of the 

Commonwealth of Pennsylvania, residing at 1843 Strahle Street, Philadelphia, PA 19152. 

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5. Plaintiff, Leslie A. Chambers is an adult individual and citizen of the 

Commonwealth of Pennsylvania, residing at 1843 Strahle Street, Philadelphia, PA 19152. 

6. Plaintiffs, Ronald E. and Leslie A. Chambers (“Chambers”), are the biological 

parents of Plaintiff, Ferren Chambers and have been appointed the guardian of the person and 

Estate of Plaintiff, Ferren Chambers by the Philadelphia Court of Common Pleas, Orphans’ 

Court Division on April 1, 2005. 

7. Defendant, School District of Philadelphia is a Pennsylvania School District, duly 

created and existing under the laws of the Commonwealth of Pennsylvania, with its Board of 

Education office located at 2130 Arch Street, Fifth Floor, Philadelphia, Pennsylvania, 19103-

1390. 

III. FACTS

8. Plaintiff, Ferren Chambers was born on October 15, 1985, via forceps assisted 

vaginal delivery at Sharon General Hospital. As a result of the forceps delivery, Plaintiff, Ferren 

Chambers had frontal and occipital bruising. Her birth weight was 7 pounds, 7 ounces, and her 

birth was complicated by meconium staining and muchal cord. Following delivery, Plaintiff, 

Ferren Chambers was lethargic and had poor appetite. 

9. At nine months of age, Plaintiff, Ferren Chambers was diagnosed as being 

developmentally delayed. 

10. At the age of 2, Plaintiff, Ferren Chambers was diagnosed with seizures and 

placed on Phenobarbital. In July, 1988, Plaintiff, Ferren Chambers experienced her first grand 

mal seizure. 

11. As Plaintiffs resided at all times relevant hereto within Defendant, School District 

of Philadelphia, Plaintiff, Ferren Chambers began her schooling in the Early Intervention 

Program at the Charles Drew School of Defendant, School District of Philadelphia at about 1 1⁄2 

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years of age. Plaintiff, Ferren Chambers was placed in a high intensity class where she received 

speech and language services. 

12. In or about 1989, Plaintiff, Ferren Chambers was transferred to the North East 

Growth and Development Center. Between February and April 1989, Plaintiff, Ferren 

Chambers’ behavior began to change. She exhibited hyperactivity, stopped talking, became 

aggressive, stopping eating food she previously enjoyed and became particularly sensitive about 

textures. 

13. In or about November 1990, Plaintiff, Ferren Chambers was evaluated by 

Defendant, School District of Philadelphia for placement and was categorized as a severely and 

profoundly impaired child, but not as autistic/pervasive developmental disorder. She was placed 

in a program for severely handicapped children and was not given appropriate educational 

services given her true medical condition. 

14. Plaintiffs Chambers removed Plaintiff, Ferren Chambers from the classroom and 

requested a conference to change her disability category and achieve a more appropriate 

placement for her. A prehearing conference with Defendant, School District of Philadelphia was 

held but the request for educational services appropriate for Plaintiff, Ferren Chambers was 

denied by the Defendant. 

15. Defendant, School District of Philadelphia sought to hold Plaintiffs, Chambers 

liable for Plaintiff, Ferren Chambers’ absence from school in truancy court, but these allegations 

were rejected by the Court given that Defendant, School District was not providing appropriate 

educational services to Plaintiff, Ferren Chambers. 

16. In July, 1991, the State Level Special Appeals Panel of the Commonwealth of 

Pennsylvania ordered that Plaintiff, Ferren Chambers to be classified as autistic/pervasive 

developmental delay. The Appeals Panel found that Plaintiff, Ferren Chambers required goals 

aimed at social relatedness, social interaction, language and activity level. The Appeals Panel 

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further found that Plaintiff, Ferren Chambers required placement is a program specifically 

designed for children with autism/pervasive developmental delay, or an autistic support program. 

Despite the foregoing, no placement in an appropriate program took place. 

17. On or about January 24, 1992, the Honorable Stewart Dalzell, for the United 

States District Court for the Eastern District of Pennsylvania, ordered the Defendant, School 

District of Philadelphia to classify Plaintiff, Ferren Chambers as a youngster with multiple 

handicapping conditions, including, but not limited to autism/pervasive developmental delay. It 

was only thereafter that Plaintiff, Ferren Chambers was placed in an autistic support program. 

18. Thereafter, Plaintiff, Ferren Chambers attended Defendant, School District of 

Philadelphia’s Greenfield School and was placed in its autistic support program and made 

progress in her language and communication skills, but Defendant, School District of 

Philadelphia subsequently stopped providing autistic support services to Plaintiff, Ferren 

Chambers. 

19. Plaintiff, Ferren Chambers began the 1994-95 school year at Defendant, School 

District of Philadelphia’s Lowesche Elementary School, in a full-time autistic support class, but 

was not provided with adequate support or instruction to allow progress of her language and 

communication skills. Thereafter, Plaintiffs Chambers requested a due process hearing because 

the Defendant, School District of Philadelphia would not reach agreement with the Plaintiffs 

with regards to Plaintiff, Ferren Chambers appropriate educational placement. The due process 

hearing request was intentionally misplaced by Defendant, School District of Philadelphia which 

enabled the Defendant to request further reevaluation of Plaintiff, Ferren Chambers. However, at 

the following Individual Education Plan (“IEP”) meeting both Defendant and Plaintiffs agreed 

that Plaintiff, Ferren Chambers required placement in a full-time Approved Private School 

(“APS”). 

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20. Despite the foregoing, the Defendant, School District of Philadelphia failed to 

place Plaintiff, Ferren Chambers into an appropriate APS even after entering into the 

aforementioned agreement between the parties. Because of the Defendant’s intentional inaction, 

Jeffrey Gonnick, Appellate Officer for the Appeals Panel, ordered the Defendant, School District 

of Philadelphia to implement the IEP by placement of Plaintiff, Ferren Chambers in an APS. 

Also, the Defendant, School District of Philadelphia was ordered to pay tuition to a neighboring 

school district to implement the IEP until the time when an appropriate APS was located. 

Furthermore, if the Defendant, School District of Philadelphia was unable to find either an 

appropriate APS or pay a neighboring school district, the Defendant was ordered to hire a special 

education teacher for 30 hours per week of one on one instruction in Plaintiff, Ferren Chambers’ 

home until she was placed in an APS. 

21. On or about July 31, 1995, the Plaintiffs, Chambers along with the Defendant, 

School District of Philadelphia developed another IEP for Plaintiff, Ferren Chambers. The IEP 

ordered the placement of Plaintiff, Ferren Chambers in an with autistic support on a full-time 

daily basis. 

22. On August 3, 1995, Plaintiff, Ferren Chambers was accepted at Wordsworth 

Academy for the 1995-1996 school year. However, Defendant, School District of Philadelphia 

failed to provide appropriate educational services to Plaintiff, Ferren Chambers pursuant to her 

IEP. 

23. On or about May 20, 1998, a settlement agreement was reached with Defendant, 

School District of Philadelphia during the course of another Due Process Hearing. Plaintiffs, 

Chambers requested the Due Process Hearing because of Defendant, Philadelphia School 

District’s failure to provide the agreed upon educational services for Plaintiff, Ferren Chambers 

while she was attending Wordsworth Academy. 

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24. On or about March 26, 1999, the Bureau of Special Education issued a report 

concerning the Defendant, School District of Philadelphia’s continued failure to implement the 

services contained in Plaintiff, Ferren Chambers’ IEP. The Bureau concluded that Defendant 

failed to deliver speech services listed in the IEP for the 1997-1998 school year, summer of 1997 

extended school year and the 1998-1999 school year. The Bureau concluded that as of March 

26, 1999, Defendant had not implemented the required speech services as established in the IEP 

for the 1997-1998 school year. 

25. On or about June 29, 1999, Plaintiffs, Chambers agreed to the proposed 

compensatory speech education for Plaintiff, Ferren Chambers, with the Defendant, School 

District of Philadelphia paying for such services. 

26. On September 4, 2001, another Due Process Hearing was held. Defendant, 

School District of Philadelphia agreed to provided the augmentative communication system that 

was recommended in the January 26th, 2001 DuPont Hospital for Children report, including 

payment for the equipment needed to implement the recommendations included in that report. 

27. Plaintiffs, Chambers sent letters on multiple occasions requesting, in part, the 

names of individuals who would be responsible for assuring that payments are promptly made 

for compensatory services provided under the terms of the September 4, 2001 agreement 

between the Plaintiffs and Defendant, School District of Philadelphia. However, the Defendant 

did not pay DuPont Hospital for Children for its report, did not comply with any of the Plaintiffs’ 

pre-hearing conference requests and did not fulfill its obligation for compliance with the 

settlement agreement, despite the Plaintiffs’ withdrawal of hearing requests based upon the 

assurances made in the settlement agreement. 

28. On or about November 19, 2001, the Special Education Appeals Panel affirmed 

the lower hearing officer’s Order that required an independent evaluation of Plaintiff, Ferren 

Chambers.

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29. Plaintiff, Ferren Chambers underwent psychiatric evaluation at Kennedy Krieger 

Institute on or about January 9, 2002. The evaluation concluded that Plaintiff, Ferren Chambers 

had not received appropriate autism education services; and had therefore progressed little 

developmentally since her initial evaluation at Kennedy Krieger Institute in 1992. 

30. The evaluation report from Kennedy Krieger Institute further indicated that: 

“Ferren’s school history and that lack of autism services have obviously prevented her from 

reaching her full potential despite her disabilities. Although, well loved and treasured by her 

family, having a chronically disabled child in the family has taken its toll on the parents and 

Ferren’s siblings. The added burden of fighting the system for appropriate services for their 

daughter has left Mr. and Mrs. Chambers with stress induced symptoms and a sense of 

hopelessness.” 

31. Additionally, Plaintiff, Ferren Chambers’ attending psychiatrist, Paula J. 

Lockhart, M.D. made the following recommendation: “Both Ferran’s (sic) autism and 

developmental delays need to be addressed educationally. Despite the lack of appropriate 

services up until this time, she could still greatly benefit from an appropriate program.” 

32. On February 14, 2002, Pennsylvania Special Education Hearing Officer, Carole 

Hite Welch tentatively decided to make a random selection of independent evaluator so that the 

Appeals Panel Order can Proceed as the Defendant could not come to an agreement with the 

Plaintiffs as the selection of an appropriate evaluator. 

33. On March 1, 2002, Jane C. Kunze, Ph.D. of the Kennedy Krieger Institute 

reported her findings of Plaintiff, Ferren Chamber’s psychological evaluation of her then current 

cognitive functioning. The report gave a description of her educational needs at that time, stating 

in part, “[c]lass placement needs to address Ferren’s level of cognitive functioning as well as her 

autistic features. She needs to be in a small class with adequate opportunity for individualized 

help with tasks and immediate behavioral intervention when needed and with an emphasis on 

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functional skills. She needs a class with at least some other children functioning around her 

developmental level. This would provide the best opportunity for encouraging interaction and 

participation in activities that Ferren can comprehend. Ferren does observe others and has 

imitated class behaviors. These abilities could be used for learning purposes in a class oriented 

more toward children of Ferren’s level of functioning. In addition, Ferren needs a placement that 

incorporated teacher strategies geared toward autistic children. Ferren needs much prompting 

and redirection to engage, maintain, and move her attention from activity to activity. She will 

need more help to become engaged in activities, particularly those that involve interactions, that 

a child of her cognitive functioning without autism. I also encourage the use of ‘watch-andlearn’ activities (‘do-what-I’m-doing’) to improve Ferren’s ability to imitate activities. It may be 

possible to gently turn some of her favorite object driven activities into more two-way interactive 

activities. It is important for those working with Ferren recognize her current levels of 

functioning in order to make appropriate expectations.” 

34. On or about April 4, 2002, Defendant, School District of Philadelphia held an IEP 

meeting without Plaintiffs, Chambers and reached a conclusion as to their perceived appropriate 

IEP goals. 

35. On or about April 17, 2002, Plaintiffs, Chambers disapproved of the IEP that was 

sent to them along with a Notice of Recommended Educational Placement (NOREP). Plaintiffs 

rejected the NOREP and IEP because it was not an appropriate plan for Plaintiff, Ferren 

Chambers; nor was the then current placement appropriate for her. 

36. According to the April 26, 2002 Due Process Hearing decision, Plaintiffs received 

independent evaluations from the Kennedy Krieger Institute as well as the DuPont Hospital for 

Children because they were not satisfied with any of the evaluators proposed by Defendant, 

School District of Philadelphia. 

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37. On or about May 11, 2002, Plaintiffs, Chambers withdrew their request for a Due 

Process Hearing because Defendant, School District of Philadelphia informed them that they 

would reconvene an IEP meeting to consider the DuPont and Kennedy Krieger evaluations. 

38. On or about May 20, 2002, the IEP Team determined that no additional data was 

required because the information from DuPont and Kennedy Krieger was sufficient. 

39. On or about May 28, 2002, the Bureau of Special Education Division of 

Compliance determined that Defendant, School District of Philadelphia continuously failed to 

implement speech services described in the 2000 IEP and also failed to provide for the 2001 

Extended School Year (ESY) services. These failures to implement Plaintiff, Ferren Chambers’ 

IEP continued through the 2003-2004 school year. 

40. On February 19, 2004, Jane C. Kunze, Ph.D., of the Kennedy Krieger Institute, 

submitted an updated evaluation of Plaintiff, Ferren Chambers. The report set forth that: 

“Ferren requires a setting that addresses her level of retardation. Goals and teaching strategies 

need to be set in accordance with her level of understanding and be functional in nature rather 

than academic. An environment that includes language and academic work that is significantly 

above her level of functioning will not offer her appropriate stimulation or opportunity to 

progress. In addition, Ferren will do best in a setting geared toward persons with autism in order 

to address her speech and attention needs.” 

41. On or about March 18, 2004, a final Due Process Hearing was held before 

Pennsylvania Special Hearing Officer, Rosemary E. Mullally, Esq. Based on her findings, the 

Hearing Officer issued an Order stating, inter alia, that the Defendant, School District of 

Philadelphia owed Plaintiffs 3,180 hours of compensatory education based on two and a half 

years of Defendant’s denial of free and appropriate public education to Plaintiff, Ferren 

Chambers, she as mandated under the law. 

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42. As a direct and proximate and proximate result of Defendant, School District of 

Philadelphia’s intentional and continuous refusal to provide clearly necessary and appropriate 

educational services to Plaintiff, Ferren Chambers, Plaintiff, Ferren Chambers has been deprived 

of a free and appropriate public education. 

43. As a direct result of Defendant, School District of Philadelphia’s intention and 

continuous refusal to provide clearly necessary and appropriate educational services to Plaintiff, 

Ferren Chambers, she has suffered permanent injuries and will not be able to develop 

communicative skills and abilities to allow her to communicate with others and to participate in 

her daily care. 

44. As a direct and proximate result of Defendant, School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services to Plaintiff, Ferren Chambers, Plaintiffs will incur future expenses for her care and 

require various therapies, which would not have to be incurred if Defendant had provided the 

educational services to Plaintiff, Ferren Chambers as requires under the law. 

45. As a direct and proximate result of Defendant, School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services, Plaintiff, Ferren Chambers has suffered severe emotional distress, frustration, disability 

and inability to learn communicative skills which will cause her to suffer even greater distress in 

the future. 

46. As a direct and proximate result of Defendant School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services to Plaintiff, Ferren Chambers, Plaintiffs, Chambers have incurred expenses and suffered 

monetary losses due to the Defendant’s intentional failure to provide educational services to 

Plaintiff, Ferren Chambers as required by law. 

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47. As a direct and proximate result of Defendant, School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services to Plaintiff, Ferren Chambers, Chambers have suffered severe emotional distress due to 

the Defendant’s intentional failure to provide educational services to Plaintiff, Ferren Chambers 

as required by law. 

48. As a direct and proximate result of Defendant, School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services for Plaintiff, Ferren Chambers, Plaintiffs, Chambers have suffered severe emotional 

distress due to Defendant’s intentional attempts to prevent them from ensuring that their 

daughter receive appropriate educational services to allow her to become communicative. 

IV. CLAIMS FOR RELIEF

COUNT I

PLAINTIFFS, RONALD E. AND LESLIE A. CHAMBERS, AS GUARDIANS OF 

FERREN CHAMBERS, AN INCAPACITATED PERSON, AND RONALD E. AND 

LESLIE A. CHAMBERS IN THEIR OWN RIGHT VS. DEFENDANT ,SCHOOL 

DISTRICT OF PHILADELPHIA

49. Plaintiffs, Chambers incorporate by reference herein all of the allegations 

contained in paragraphs 1 through 48 inclusive, as though same were set forth in their entirety. 

50. Plaintiff, Ferren Chambers is disabled as defined by the Rehabilitation Act of 

1973. 

51. Plaintiff, Ferren Chambers was otherwise qualified to participate in the of the 

School District of Philadelphia during all time periods relevant herein. 

52. Defendant, School District of Philadelphia had received federal financial 

assistance during all times of its failure to provide Plaintiff, Ferren Chambers with a free and 

appropriate public education. 

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53. Plaintiff, Ferren Chambers was intentionally excluded from participation in, 

denied the benefits of, and subject to discrimination at the various schools of the Defendants, 

School District of Philadelphia. 

54. Defendant, School District of Philadelphia violated the IDEA and Section 504 of 

the Rehabilitation Act of 1973 as a matter of practice and policy by intentionally and 

continuously failing to provide Plaintiff, Ferren Chambers with a free, appropriate public 

education and related educational services by repeatedly and intentionally: 

(a) refusing to schedule mandatory conference with Plaintiffs, Chambers; 

(b) intentionally misplacing requests for hearings related to Plaintiff, Ferren 

Chambers; 

(c) failing to establish appropriate IEP for Plaintiff, Ferren Chambers; 

(d) failing to comply with Plaintiff, Ferren Chambers’ IEP after it had agreed to it; 

(e) failing to comply with agreements concerning carrying out the IEPs; and 

(f) refusing to honor orders and agreements to provide educational services to 

Plaintiff, Ferren Chambers 

Wherefore, Plaintiffs, Chambers, as guardians of Ferren Chambers, and in their own 

right, demand judgment against Defendant, School District of Philadelphia in an amount in 

excess of One Hundred Fifty Thousand Dollars ($150,000) in compensatory and punitive 

damages with lawful interest thereon, attorneys’ fees and costs of suit and brings this action to 

recover same. 

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COUNT II

PLAINTIFFS, RONALD E. AND LESLIE A. CHAMBERS, AS GUARDIANS OF 

FERREN CHAMBERS, AN INCAPACITATED PERSON AND RONALD E. AND 

LESLIE A. CHAMBERS IN THEIR OWN RIGHT VS. DEFENDANT ,SCHOOL 

DISTRICT OF PHILADELPHIA

55. Plaintiffs, Chambers incorporate by reference herein all of the allegations 

contained in paragraphs 1 through 54 inclusive, as though same were set forth in their entirety. 

56. The intentional actions of Defendant, School District of Philadelphia detailed 

hereinabove violated Plaintiff’s constitutional due process rights by violating Plaintiff, Ferren 

Chambers’ rights granted under Section 504 of the Rehabilitation Act of 1973 and IDEA. 

57. As a direct result of Defendant, School District of Philadelphia’s intentional and 

continuous refusal to provide clearly necessary and appropriate educational services to Plaintiff, 

Ferren Chambers, she has suffered permanent injuries and will not be able to develop 

communicative skills and abilities to allow her to communicate with others and to participate in 

her daily care. 

58. As a direct and proximate result of Defendant, School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services to Plaintiff, Ferren Chambers, Plaintiffs will incur future expenses for her care which 

would not have to be incurred if Defendant had provided the educational services to Plaintiff, 

Ferren Chambers as requires under the law. 

59. As a direct and proximate and proximate result of Defendant, School District of 

Philadelphia’s intentional and continuous refusal to provide clearly necessary and appropriate 

educational services, Plaintiff, Ferren Chambers has been deprived of a free and appropriate 

public education. 

60. As a direct and proximate result of Defendant, School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

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services for Plaintiff, Ferren Chambers, Chambers have suffered severe emotional distress due to 

the Defendant’s intentional failure to provide educational services to Plaintiff, Ferren Chambers 

as required by law. 

61. As a direct and proximate and proximate result of Defendant, School District of 

Philadelphia’s intentional and continuous refusal to provide clearly necessary and appropriate 

educational services to Plaintiff, Ferren Chambers, Plaintiffs, Chambers have suffered severe 

emotional distress due to Defendant’s intentional attempts to prevent them from ensuring that 

their daughter receive appropriate educational services to allow her to become communicative. 

62. As a direct and proximate result of Defendant School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services to Plaintiff, Ferren Chambers, Plaintiffs, Chambers have incurred expenses and suffered 

financial losses due to Defendant’s intentional failure to provide educational services to Plaintiff, 

Ferren Chambers as required by law. 

 Wherefore, Plaintiffs, Chambers, as guardians of Ferren Chambers, and in their own 

right, demand judgment against Defendant, School District of Philadelphia in an amount in 

excess of One Hundred Fifty Thousand Dollars ($150,000) in compensatory and punitive 

damages with lawful interest thereon, attorneys’ fees and costs of suit and brings this action. 

COUNT III

PLAINTIFFS, RONALD E. AND LESLIE A. CHAMBERS, AS GUARDIANS OF 

FERREN CHAMBERS, AN INCAPACITATED PERSON VS. DEFENDANT ,SCHOOL 

DISTRICT OF PHILADELPHIA

63. Plaintiffs, Chambers incorporate by reference hereto all of the allegations 

contained in paragraphs 1 through 62 inclusive, as though same were set forth in their entirety. 

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64. The intentional actions of Defendant, School District of Philadelphia constitute 

intentional discrimination and reckless and deliberate indifference to Plaintiff, Ferren Chambers’ 

constitutional rights in violation of the Equal Protection clause of the United State Constitution. 

65. As a direct and proximate and proximate result of Defendant, School District of 

Philadelphia’s intentional and continuous refusal to provide clearly necessary and appropriate 

educational services to Plaintiff, Ferren Chambers, Plaintiff, Ferren Chambers has been deprived 

of a free and appropriate public education. 

66. As a direct result of Defendant, School District of Philadelphia’s intention and 

continuous refusal to provide clearly necessary and appropriate educational services to Plaintiff, 

Ferren Chambers, she has suffered permanent developmental injuries and will not be able to 

develop communicative skills and abilities to allow her to communicate with others and to 

participate in her daily care. 

67. As a direct and proximate result of Defendant, School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services to Plaintiff, Ferren Chambers, Plaintiffs will incur future expenses for her care which 

would not have to be incurred if Defendant had provided the educational services to Plaintiff, 

Ferren Chambers as requires under the law. 

68. As a direct and proximate result of Defendant School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services to Plaintiff, Ferren Chambers, Plaintiffs, Chambers have incurred expenses and suffered 

financial losses due to Defendant’s intentional failure to provide educational services to Plaintiff, 

Ferren Chambers as required by law. 

69. As a direct and proximate and proximate result of Defendant, School District of 

Philadelphia’s intentional and continuous refusal to provide clearly necessary and appropriate 

educational services for Plaintiff, Ferren Chambers, Plaintiffs, Chambers have suffered severe 

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emotional distress due to Defendant’s intentional attempts to prevent them from ensuring that 

their daughter receive appropriate educational services to allow her to become communicative. 

70. As a direct and proximate result of Defendant, School District of Philadelphia’s 

intentional and continuous refusal to provide clearly necessary and appropriate educational 

services to Plaintiff, Ferren Chambers, Chambers have suffered severe emotional distress due to 

the Defendant’s intentional failure to provide educational services to Plaintiff, Ferren Chambers 

as required by law. 

 Wherefore, Plaintiffs, Chambers, as guardians of Ferren Chambers, and in their own 

right, demand judgment against Defendant, School District of Philadelphia in an amount in 

excess of One Hundred Fifty Thousand Dollars ($150,000) in compensatory and punitive 

damages with lawful interest thereon, attorneys’ fees and costs of suit and brings this action. 

V. JURY DEMAND

 Plaintiffs demand trial by jury. 

ANAPOL, SCHWARTZ, WEISS, COHAN, 

FELDMAN & SMALLEY, P.C. 

 _____________________________________ 

BY: ALAN SCHWARTZ, ESQUIRE 

 STEPHEN J. POKINIEWSKI, JR., ESQUIRE 

 I.D. Nos. 04217 AND 45186 

 1900 Delancey Place 

 Philadelphia, PA 19103 

 (215) 735-1130 

 ATTORNEYS FOR PLAINTIFFS 

Dated: ______________ 

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VERIFICATION

 Stephen J. Pokiniewski, Jr., Esquire, hereby states he is Counsel for the Plaintiffs in this 

action and verifies the statements made in the foregoing Civil Action Complaint are true and 

correct to the best of his knowledge, information and belief. The undersigned understands that 

the statements therein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn 

falsifications to authorities. 

 

_____________________________________ 

 STEPHEN J. POKINIEWSKI, JR., ESQUIRE 

DATED: _________________________ 

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