Report to the Board of Trustees of Trinity School

The content of this report is sensitive, personal, and graphic. It is not intended for children. Reader discretion is advised.

Nancy Kestenbaum Jason P. Criss Covington & Burling LLP January 2020

I. Introduction In September 2018, Head of School John Allman wrote to the Trinity School community to report that Phillips Exeter Academy had recently issued a report describing possible sexual misconduct by members of the Exeter faculty and staff, including a former teacher at Exeter, Henry Ploegstra. The September 2018 message also explained that Ploegstra had taught at Trinity after leaving Exeter. Allman invited any member of the Trinity School community who had any concerns or issues that they would like to raise to contact him. No one responded to the September 2018 message with information about Ploegstra, but some former students reported information about other former Trinity faculty members. On March 14, 2019, Allman and the Board of Trustees President sent out a follow-up letter to the school community. That letter explained that in response to the September 2018 message, the school had received several reports of sexual misconduct or harassment by former faculty and that the Board had asked Covington & Burling LLP to investigate reports the school had already received, and to investigate any new reports of sexual misconduct against any student by Trinity School faculty or staff, review records of any reports of sexual misconduct the school received in the past, and conduct additional investigation or follow-up that Covington determined was warranted. The March 2019 letter provided an email and telephone hotline that members of the Trinity community could use to contact us. Trinity informed us that it sent this message by email to 7,750 individuals and by physical mailing to 8,644 individuals, including all of the email addresses in the school’s database for Upper School students, and all of the email and mailing addresses in the school’s database for former students, current and former faculty and staff, current and former trustees, and current and former parents and grandparents of students. II. Investigative Process Twenty-six former students and two Trinity employees contacted our hotline to provide information. No current Trinity students contacted the hotline, and we did not receive any reports about potential sexual misconduct by current Trinity faculty or staff involving Trinity students. We interviewed everyone who contacted our hotline to provide first- or second-hand information about potential adult sexual misconduct involving Trinity students. We also contacted and interviewed former students who had contacted the school previously to report sexual misconduct by former faculty members. Consistent with best practices for investigations concerning sexual misconduct involving minors, we did not directly contact former Trinity students who might have experienced sexual misconduct unless the former students first contacted us. We also requested and conducted interviews of current and former faculty members, school administrators, and others whom we identified as potentially having relevant information. In total, we interviewed 50 individuals, including

former Trinity students, current and former Trinity administrators and teachers, and parents of former students. We also reviewed a variety of documents relevant to the issues we investigated, provided by the school and by others. We wrote to all of the living former Trinity faculty members who were the subject of reports of sexual misconduct whom we considered naming in this report and asked to speak with them. We note below if we interviewed a particular individual accused of sexual misconduct, if the individual declined or did not respond to our request for an interview, if he or she declined to answer our questions but provided us with a statement directly or through counsel, or if the former teacher is deceased. Trinity did not impose any limitations on our work and gave us the autonomy to conduct a thorough investigation. The school provided us with access to all of the documents that we requested, and helped us locate and contact people with whom we wished to speak. III. Criteria for Inclusion in this Report and Confidentiality A key issue we confronted when preparing this report was whether each faculty member accused of sexual misconduct should be included in this report, and whether we should name him or her. We carefully considered this question for each individual we investigated and we reached different decisions based on a number of factors, including the scope of our mandate and the information we learned. We made a holistic assessment regarding each individual’s reported conduct, rather than trying to follow a strict formula. The factors we weighed when deciding whether an adult accused of sexual misconduct should be described or named in this report are as follows: • Our mandate to investigate all reports of adult sexual misconduct against any student by Trinity faculty or staff that we received or could find, and to conduct any additional investigation or follow-up as we decided was warranted. • The severity of the individual’s reported conduct. • Whether we received direct, first-hand reports about the individual. • Whether we received credible reports of the individual having engaged in incidents of sexual misconduct with multiple students. • Whether we were able to corroborate the incidents described to us and the amount and quality of this corroborating evidence. • In the case of reported conduct that was more ambiguous, whether the students who experienced and reported the conduct perceived it to be sexual misconduct.

2 After weighing these factors, we decided to name two teachers, described in Section IV. We decided to describe, but not name, six other teachers, whom we identify as Teacher A through Teacher F. The reports we received about those six teachers are described in Section V. Finally, there were five faculty members who were the subject of less specific or less serious reports than the reports about Teachers A-F; they are described briefly at the end of Section V.1 We are not naming any former Trinity students in this report. Instead, we are referring to certain former Trinity students with a numerical identifier such as “Student 1.” Where appropriate, given their involvement in responding to incidents described below, we are naming certain current or former senior Trinity administrators we contacted and interviewed, or who were involved in the school’s responses to misconduct reports. IV. Teachers Named in this Report Based on the investigation we conducted, and after weighing the factors enumerated above, we decided to name two former teachers who were the subject of multiple first-hand reports of sexual misconduct: Larry Cantor and Robert Kahn. A. Larry Cantor Larry Cantor taught physical education at Trinity from 1968 to 1972 and from 1979 to 1983, and he also coached wrestling, track, and cross-country. We received first-hand reports of sexual misconduct by Cantor that took place over a decade, from both periods of Cantor’s employment at Trinity. These reports came from male members of classes of the mid-1970s (Students 1 and 2), early 1980s (Student 3), and mid-1980s (Students 4 and 5). Students 1-4 described misconduct they experienced in connection with wrestling practices at Trinity and Student 5 described similar misconduct on a camping trip. All five former students described conduct that they recognized went well beyond acceptable contact between a wrestling coach and student athlete. Student 1 reported that when he was in middle school, Cantor told Student 1 that he had a “wrestling hold” he wanted to show him, even though Student 1 was not on the wrestling team. Cantor and Student 1 walked into the wrestling room and got down on the wrestling mat together in a horizontal position. According to Student 1, Cantor proceeded to put Student 1 in a headlock and hold him on the mat until Cantor sexually climaxed, which happened quickly. Student 1 told us that he told two of his friends from Trinity about this incident after they had graduated from high school. He put us in touch with one of these friends, who confirmed that in the past ten or fifteen years, Student 1 told him that Cantor had

1 As noted above, Trinity did not receive any reports about Ploegstra in response to its September 2018 message. We also did not receive any reports about Ploegstra.

3 rubbed against Student 1 to “pleasur[e] himself” under the guise of showing Student 1 a wrestling move. In 2010, Student 2 provided Trinity with a written statement that primarily discussed Student 2’s sexual relationship with a different former Trinity teacher that began after Student 2 had graduated from Trinity. In that statement, Student 2 also described misconduct by Cantor that Student 2 experienced when he was in middle school. Student 2 wrote, “Everyone knew about Cantor. He would find a boy and hold him back after class and wrestle (shirtless now, so as to toughen the skin for the mat, or so he claimed). Cantor chose me one term to be [h]is wrestling buddy and while I sensed there was something wrong about it I went along with it. On one occasion there was the distinct wet-spot on his shorts which signaled he had cum.” We asked to speak with Student 2, but he declined our request.2 Student 3 told us that when he was in high school, Cantor would urge him or other members of the wrestling team to stay after practice for extra individual coaching. According to Student 3, during these sessions, which began when Student 3 was 13 years old, Cantor would turn off most of the lights, and start wrestling with Student 3, possibly with the gym door locked. Cantor would usually ask Student 3 to remove his t-shirt or the straps of his wrestling singlet, and then they would wrestle, with Cantor ending up on his back with Student 3 on top of him, in what Student 3 described as a “full body hug.” Student 3 said that Cantor would often moan or grunt quietly with his head buried into Student 3’s shoulder during these sessions. He described the encounters as involving “intimate contact through our clothes, but no outright sexual act.” He described Cantor as being “clearly aroused in some way” during the sessions, and that in one session, Cantor held his hand on Student 3’s genitals. Student 3 said that he was “reasonably sure I went with the coach [to these one-on-one sessions] at least six to a dozen times each [wrestling] season, perhaps less senior year.” He said that over these sessions, the amount of time spent practicing wrestling decreased, and the amount of time Cantor spent hugging him increased. He also said that he now believes that Cantor “was grooming me for abuse: isolating me, avoiding discovery, and setting up a liminal situation in hopes that I would respond further, all while maintaining plausible deniability.” Student 3 reported that other members of the wrestling team participated in one-on-one wrestling sessions with Cantor, or that Cantor sought to engage in one-on-one sessions with them. He also reported that on one trip to a wrestling tournament, Cantor suggested that Cantor and Student 3 share a hotel room, but that Student 3 refused. Student 4 told us that he was a member of the Trinity wrestling team in seventh and eighth grades. He described Cantor engaging in physical contact with wrestlers that Student 4 considered to be improper. Student 4 said that Cantor

2 We did not receive any other reports regarding the other teacher described in Student 2’s written statement, and, as noted above, Student 2 declined to speak with us.

4 “would get off on me” when purportedly showing him wrestling moves in one-on-one sessions. He also recalled that Cantor would shower with students in an open shower room, which he described as “grossly inappropriate.” Student 5 told us that when he was in eighth grade, he went on a camping trip with Cantor, another teacher, and two other Trinity students. He said that on the trip, the other teacher and the three students slept in a tent, but Cantor slept at a nearby motel. During the trip, Cantor suggested to Student 5 that they go to his motel room to practice wrestling moves, because Student 5 had recently tried out for Trinity’s wrestling team. There, Cantor and Student 5 engaged in conduct that Student 5 described as “really not wrestling but him trapping me on the bed … holding me down in a mock wrestling pose and panting heavily.” Student 5 said that he believed that Cantor was sexually aroused during the encounter, and that Cantor may have sexually climaxed. None of the former students said that they reported misconduct by Cantor to the school administration or to other faculty members, and Cantor’s personnel file does not include any documents referring to potential misconduct. However, Robin Lester, Trinity’s Headmaster from 1975 to 1986, recalled that Upper School Principal John Hanly “handled the monitoring of Cantor.” This would have taken place during Cantor’s second period of employment at Trinity, as Lester was not at Trinity, and Hanly was a teacher, but not an administrator, during Cantor’s first period of employment. Lester recalled that Hanly told Cantor not to hold weekend wrestling practices at the school. Lester could not recall if there was a specific report that prompted Hanly’s instruction, but he said that it may have been because students were not comfortable when they were practicing with Cantor or that Cantor got erections when working out with the wrestlers. Trinity informed us that Hanly is incapacitated and would not be able to communicate with us. A teacher who joined the Trinity faculty after Cantor had left said that when two or three former wrestlers visited the school, the former students rolled their eyes and became visibly uncomfortable when Cantor was mentioned, and suggested that Cantor was too “hands-on” or “touchy-feely.” Cantor left Trinity in 1983 to become the athletic director of an independent school in upstate New York. His Trinity personnel file does not provide any indication of the reasons why he left Trinity in 1972 and in 1983, and it does not include a recommendation letter or other documents indicating whether Trinity assisted him in securing other positions. The personnel file also does not include any references to reports of sexual misconduct by Cantor. Over the following decades, he has continued to be involved in interscholastic and amateur wrestling as a coach, commissioner, and official, including service as the wrestling commissioner for the New York City Public Schools Athletic League and as New York City Wrestling Chairman. He also has served as the Public Schools Athletic League’s lacrosse commissioner.

5 In our discussions with Cantor’s counsel, we informed them that we had received first-hand reports of sexual misconduct by Cantor from five former students and we provided them with a summary of the reports we received. Cantor, through counsel, ultimately declined our interview request. Cantor’s counsel cited factors including his age, the passage of time since the reported misconduct, and our decision not to provide them with additional details of the reports we received prior to an interview as reasons for declining our request. His attorneys told us that Cantor “vehemently denies” engaging in sexual misconduct with Trinity students, that the “wrestling room at Trinity was open and fully visible to anyone both during practice and in private coaching sessions” and that “he never acted inappropriately toward any student and especially not in a hotel room only partially dressed.” They also stated that “moves and maneuvers that were engaged in by Coach Cantor may have been critical to wrestling training for leverage and advantage over an opponent and not designed for sexual gratification.” B. Robert Kahn Robert Kahn taught history at Trinity from 1978 to 1989. He also managed textbook orders for the school starting in 1984. Trinity terminated Kahn’s employment in 1989, after the school determined that he had used his textbook position to misappropriate more than $230,000 in school funds. Two Trinity graduates, Students 6 and 7, reported misconduct by Kahn on summer trips he chaperoned. They explained that the trips were organized by outside tour companies, that Kahn recruited small groups of Trinity students to go on these trips with him, and that the trips included other participants who were not affiliated with Trinity. We were not able to determine what role, if any, Trinity played in sponsoring these trips or facilitating students’ participation in them. Student 6 told us that he traveled with Kahn and other Trinity students to Europe in the early 1980s. Student 6 said that he was 13 years old when he went on this trip with Kahn, during the summer between his seventh and eighth grade years. Student 6 said that during the trip, Kahn told Student 6 that Student 6 was not sleeping well, and Kahn gave him a pill to take. After approximately ten minutes, Student 6 told Kahn that he did not yet feel the effects of the pill, and Kahn gave him another pill, which Student 6 also took. Student 6 said that he passed out after taking the second pill, and that he does not know exactly what happened while he was asleep. However, he concluded that Kahn “wanted to drug me in order to molest me, whatever he did.” When Student 6 woke up, it was more than 24 hours later, he was still in Kahn’s hotel room, and Kahn had left the room. Student 7 told us that in the early 1980s, during the summer between eighth and ninth grades, when he was 13 years old, he went on a summer trip with Kahn to Europe, with another Trinity student and others. That trip took place approximately two years after the trip described by Student 6. Student 7 recalled that during that trip, Kahn held the students’ travelers checks, and near the end of the trip, Kahn insisted that Student 7 come to his room to collect his checks. When

6 Student 7 arrived at Kahn’s room, Kahn was in his underwear, and Kahn wrestled with him before Student 7 threw Kahn off of him and left the room. Student 7 also described hearing, before that trip to Europe, another Trinity student say, “‘Kahn is a dangerous man, stay away from him.’” Student 7 told us that the summer after the trip to Europe, he was one of three Trinity students who traveled with Kahn to Asia and Hawaii, when Student 7 was 14 years old. Student 7 said that near the end of the trip, he almost passed out on a train, and now believes that Kahn may have drugged his drink. When the group was in Hawaii at the end of trip, Kahn told Student 7 that Student 7 was sick, and Kahn insisted that Student 7 stay in Kahn’s room and rest. He recalled that Kahn gave him something which made him “semi-pass out” and that Kahn insisted that Student 7 rest on Kahn’s bed naked while Kahn went to dinner with the other students. Student 7 recalled that one of the other students tried to enter Kahn’s hotel room to find out what was going on, but that Kahn prevented that other student from entering. Student 7 said that when Kahn returned to the room after the dinner, Kahn questioned why Student 7 had put his underwear back on. Kahn also insisted that Student 7 drink a piña colada Kahn had brought back to the room, which Student 7 now believes had a drug mixed in it. Student 7 said that Kahn then touched Student 7’s upper stomach, chest, and genitals. Student 7 recalled waking up more than 24 hours later in the hotel room he was sharing with the other boys. He did not know how he was moved from Kahn’s room to the other hotel room. Student 7 explained that he contacted Trinity in the early 1990s to inform the school about what Kahn had done. He said that he spoke to Headmaster Henry “Hank” Moses (who is deceased), with whom he said he met twice, as well as former Trinity administrators who were no longer at the school but who had worked at Trinity when Student 7 was a student, including Hanly and Upper Middle School Principal Donald Graff. We interviewed Graff, who told us that he did not remember any conversations concerning Kahn and accounts of sexual misconduct or improper touching. A decade later, Student 7 contacted Trinity again about Kahn. In 2003, he wrote a letter to Moses, which Trinity had in its files. In that letter, Student 7 referred to his prior meeting with Moses and how he had sought Moses’s help in locating Kahn. Student 7 also wrote that in the earlier meeting he had told Moses that Kahn had “drugged me and sexually molested me on a summer student trip that was sponsored by Trinity.” Student 7 wrote that in the earlier meeting, Moses had told him that the school did not have a legal obligation to do anything about Kahn. In his 2003 letter, Student 7 said that Trinity had an ethical obligation to ensure that Kahn was no longer working with children, and criticized Moses for Trinity’s recent messages to the school community about the importance of teaching ethics at Trinity. Student 7 explained to us that he wrote this letter because he felt

7 that Trinity’s messages were inconsistent with the misconduct he experienced and the school’s reaction to his earlier request about Kahn. In addition to the reports from Students 6 and 7, we received a report from an attorney for a former student (Student 8) who says that he experienced sexual misconduct by Kahn in Kahn’s classroom, as well as two first-hand reports of Kahn touching students inappropriately in his classroom from Students 9 and 10. The attorney for Student 8 declined our request to interview Student 8, but he provided us with a summary of the sexual misconduct Student 8 says he experienced in the 1970s, when Student 8 was a middle school student. The attorney provided us with additional details about the incident, but he requested that we not divulge those additional details. Student 9 reported that Kahn was his history teacher in eighth grade, in the early 1980s. He described meeting with Kahn in Kahn’s classroom to receive extra help with his schoolwork. Kahn directed Student 9 to sit on his lap and then Kahn put his hands inside Student 9’s button-down shirt and squeezed his torso. Student 9 said that he told his mother about the incident, and that he and his mother met with Graff about it. Student 9 said that he could not remember details of that meeting, but that he did not recall any action by the school in response to the information he and his mother provided. As noted above, when we interviewed Graff, he said that he did not remember any conversations concerning Kahn and accounts of sexual misconduct or improper touching. Student 9 told us that he also discussed the incident with two friends from Trinity after they had graduated. We spoke with one of them, who recalled witnessing Kahn putting his hands inside Student 9’s shirt. Student 9 said that this incident took place outside of class, but his friend recalled that Kahn did this in front of other students, during class. Student 9’s friend also described Kahn as very physical with students. He said that Kahn “would roughhouse and sort of slap you around, rub shoulders. And the boys joked about it behind his back, you know ‘getting a rub down from Mr. Kahn.’” Student 9’s friend said that this incident with Student 9 went beyond the sort of “roughhousing” by Kahn that other students experienced and discussed. Student 9’s friend also recalled that within the past five or ten years, Student 9 told him about his meeting with Graff about Kahn, after issues of sexual misconduct at independent schools became the subject of press attention, but before we began this investigation. Student 10 reported that Kahn was his history teacher during seventh grade, in the early 1980s. At the end of one class, Kahn was speaking with Student 10 and a few of Student 10’s friends. Student 10 described how Kahn “sat me on his lap, unbuttoned a button on my shirt and touched my chest,” in front of the other students. Student 10 said that when he was a senior, he described the incident to his faculty advisor. Student 10 said that he believed that the faculty advisor took the report seriously and seemed very angry about what Student 10 had described to

8 him. We interviewed the faculty advisor, who left Trinity in the late 1990s. He did not recall any student raising concerns about Kahn. In addition to Students 8-10, and Student 9’s friend, six other former students reported experiencing and witnessing other forms of physical contact between Kahn and students in his classroom, including Kahn mussing students’ hair and massaging their shoulders. Several former students also described how Kahn would be alone with students in his textbook office in the school basement. They said that students worked for him in that office organizing textbooks, and that Kahn had various gadgets in his office he would show students there, sometimes with the office door closed and the lights off to demonstrate light-up gadgets. None of these students reported witnessing or hearing about potential misconduct in the textbook office, but the faculty advisor described above recalled that another teacher conveyed to him rumors or innuendo about Kahn supervising middle school boys in that office. Kahn’s personnel file includes a number of documents relating to the theft of school funds and his separation related to that issue, but it does not contain any documents related to reports of sexual misconduct and does not include any information about subsequent employment or any recommendation letter. We were not able to determine if Kahn taught at other schools after Trinity. Student 7 told us that when he met with Hanly in the early 1990s, Hanly told him that he believed that Kahn taught at a yeshiva after Trinity. Student 7 said that he tried to locate Kahn at that time, but that he could not find him. We wrote to Kahn at his home address to request an interview, but he did not respond to our letter. V. Reports Regarding Other Former Faculty In addition to the reports about Cantor and Kahn, former Trinity students provided us with first-hand reports regarding five other former teachers. We also received second-hand information about a sixth former teacher. Below are summaries of the information we learned about these six teachers. A. Teacher A Teacher A taught at Trinity in the early 1970s. Student 11 reported that Teacher A was her teacher during her junior year and was also the faculty advisor for one of her extracurricular activities. She described spending time with Teacher A outside of school during her senior year, which she described as them “seeing each other.” She said that they had sexual intercourse once during that year, which she believed took place after she turned 18. Student 11 also reported that Teacher A was fired during that school year for other, non-sexual misconduct, and she said that she could not recall if the intercourse took place before or after his termination, although she believed it likely was before. Trinity informed us that it no longer has Teacher A’s personnel file, and therefore we could not confirm the circumstances and timing of his departure.

9 Student 11 told us that during her senior year, she told her parents (now deceased) about her relationship and sexual intercourse with Teacher A, and that after Trinity fired Teacher A, her parents helped him secure a job offer from the company where her father worked. She also identified two classmates who she said had information about her relationship with Teacher A. We spoke to both of these classmates. One confirmed that Student 11 told him in 1989 that she had a sexual relationship with Teacher A; the other recalled rumors from when they were students that Student 11 and Teacher A were in a relationship. Teacher A declined to be interviewed. In an email to us, he wrote, “I am simply not guilty of sexual misconduct.” B. Teacher B Teacher B taught at Trinity from the early 1970s through the early 1980s. His contract was not renewed when Lester, the Headmaster, learned that he was engaged in a romantic relationship with a student. Lester told us that he spoke to Teacher B about the relationship during Teacher B’s final year on the Trinity faculty, and that Teacher B acknowledged the relationship. Documents in Teacher B’s personnel file indicate, and Lester confirmed, that Lester consulted with Trinity’s regular outside counsel regarding the relationship and the school’s decision not to renew Teacher B’s contract. After leaving Trinity, Teacher B married that former student (who had graduated). Several years later, Lester supported Teacher B’s application to teach at an all-male independent school, and he provided a reference to the other school’s headmaster. Lester told us that he told the other headmaster the reason why Teacher B had left Trinity. According to publicly-available information, Teacher B taught at that school until his retirement. Three former students contacted us to report their understanding that Teacher B engaged in sexual misconduct with other female Trinity students prior to the relationship that led to his departure from the school. However, we did not receive first-hand reports of sexual misconduct by Teacher B from any of these students and there is no mention of them in Teacher B’s personnel file. Lester said that he was not aware of potential misconduct by Teacher B until he learned about the relationship described above. Teacher B, through counsel, stated that he “has no reason to believe any firsthand accounts of misconduct will surface during the course of []our investigation” and declined our request for an interview. C. Teacher C Teacher C taught music at Trinity in the mid-1980s. Student 12 reported that when he was a sophomore, Teacher C offered to provide him with private voice lessons. During a lesson, Teacher C put his hand on Student 12’s diaphragm to show proper breathing technique. Student 12 said that as he performed vocal

10 exercises, Teacher C moved his hand lower and lower on Student 12’s abdomen, until Teacher C had his hand on Student 12’s genitals. Student 12 said that he then realized that Teacher C’s touching was inappropriate, he pulled away, and he did not participate in any other private lessons with Teacher C. Student 12 also reported that after this incident, he went on an overnight trip with Teacher C to visit a composer. When Student 12 and Teacher C arrived at the home where they would be staying, Student 12 realized that he would be expected to share a bedroom with Teacher C. Student 12 said that he refused and “it was clear that [Teacher C] was upset that I insisted on staying in the living room.” We spoke with Student 12’s father, who confirmed that Student 12 went with Teacher C on this overnight trip, and that in recent years, Student 12 told him that Teacher C had tried to touch him inappropriately. Student 12 said that, during that school year, he understood that Teacher C engaged in similar, or more significant, misconduct with at least one other student. He recalled that near the end of that school year, the parents of a different student complained to the school about Teacher C’s behavior. In response, Teacher C’s department chair spoke to several male students, including Student 12, and asked them about their interactions with Teacher C. We did not receive reports from other Trinity students about Teacher C. Teacher C left the school at the end of that school year, and he later taught at another independent school in New York City, and at a university in upstate New York. We did not locate a reference letter or any other records indicating what role, if any, Trinity played in his hiring at these schools. In the late 1990s, Teacher C pled guilty in another state to sexual offenses involving minors. He died in 2019. D. Teacher D Student 12 also reported sexual misconduct the following school year by Teacher D, Teacher C’s replacement. Student 12 described how his student-teacher relationship with Teacher D became a relationship in which Student 12 was attracted to her and Teacher D was “obsess[ed]” with him. Student 12 said that he spent time with Teacher D one-on-one, both inside and outside of school, they kissed, and “maybe [there was] some fondling and groping, but no clothes came off.” Student 12 said that one of his friends eventually told Student 12’s parents about the relationship, and Student 12’s parents alerted Hanly, who was the Acting Headmaster at the time. According to Student 12, after his parents spoke to Hanly in the late fall, the school instructed Teacher D to keep her distance from Student 12. She did this until the day before winter break, when Teacher D told Student 12 that she had a holiday gift for him. According to what Student 12 told us and had previously posted on Facebook, he went to Teacher D’s office, where she kissed him and threw him against the wall with what Student 12 described in the Facebook post as “sexual aggression.” Student 12 reported the incident to Upper School Principal Suellyn Preston Scull, and Trinity terminated Teacher D.

11 As noted above, we interviewed Student 12’s father, who recalled that Teacher D paid a lot of attention to Student 12 that fall. He also recalled that one of Student 12’s friends told him that Teacher D was “‘having a relationship with’” Student 12 and that “‘she’s in love with him.’” Student 12’s father recalled speaking to Hanly about Teacher D’s relationship with Student 12. He also said that that he learned in recent years that Teacher D had kissed Student 12. Teacher D’s personnel file includes a memorandum stating that Teacher D had resigned from the faculty “effective the last day of the first semester” and that the school had agreed to pay for her to receive counseling after her departure. The file also includes a check request to pay for her counseling. The file does not include any information about Teacher D’s subsequent employment, and it does not include a Trinity reference letter. Through counsel, Teacher D declined to speak with us. Her lawyer wrote that, “There was no sexual misconduct on [her] part, nor any conduct on her part that could reasonably construed as amounting to sexual misconduct or grooming. There was nothing in [her] intellectual or artistic intimacy with students which involved any surreptitious behaviour or inappropriate emotional or physical intimacy. The circumstances of her departure, whilst upsetting to her (hence her being offered counselling as a result), are therefore of little relevance to the report that you are preparing.” E. Teacher E Teacher E taught at Trinity from the 1970s until his retirement in the early 2010s. Students 13 and 14 reported encounters with Teacher E in the mid-1980s. According to Student 13, just before winter break, Teacher E asked her to stay behind after class because he had a present for her. He then presented her with a book and a Christmas ornament. She recalled that Teacher E positioned himself between Student 13 and the classroom door, locked the door, and “came at” her in a way she described as “scary.” Student 13 described Teacher E’s conduct as him “corner[ing] me … in a very calculated way.” Student 13 said that she recognized that she had to get out of the classroom, and that she “knew that there was no one in hallways, so no one can hear me, or help me,” so she pushed past Teacher E and fled the classroom. She also made clear to us that she believed that Teacher E was trying to “molest” her. Student 14 reported that she was in Teacher E’s class in ninth or tenth grade. During the last week of her senior year (when Teacher E was not one of her teachers), Teacher E called her into his classroom, locked the door, told her he loved her, and gave her a religious book. She said that students started to bang on the door to enter, and that she then left the room. She did not recall Teacher E touching her. She said that she felt at the time that it was “disturbing” that Teacher E said that he loved her, but that she did not believe that the incident was “overly sexual.”

12 Students 13 and 14 both told us that they described their experiences with Teacher E to the same fellow Trinity graduate, who is a classmate of Student 14. Student 13 said that she described the incident to Student 14’s classmate when they were in college. We spoke to Student 14’s classmate, who said that Student 13 recently told her about the incident, but she did not recall an earlier discussion with Student 13 about it. Student 14 told us that she described the incident to her classmate soon after it took place. Student 14’s classmate recalled that discussion soon after the incident, in which Student 14 told her “something like, ‘[Teacher E] really freaked me out, he tried to lock me in the room, and told me he loved me.’” She said that Student 14 also spoke to her about her experience with Teacher E more recently. We interviewed Teacher E, and he acknowledged giving gifts to about ten students, both male and female, over the course of his tenure. He said that when he gave students these gifts, he typically did so when other students were not present, to avoid suggestions of favoritism. He said that he would ask the recipient not to tell his or her classmates, because he did not want other students to know about the gift, but he assumed that the recipient would tell his or her parents. He also said that he gave some of these gifts in his classroom with the door closed, and that he sometimes locked the classroom door, because he did not want other students to come in and see that he was giving a gift to one student. Teacher E also said that, in one-on-one meetings, he likely hugged students and told them that he loved them, but he denied having romantic or sexual intent when doing so. Teacher E’s personnel file includes several documents related to complaints from students about Teacher E’s behavior that made them uncomfortable. In 1991, Headmaster Christopher Berrisford sent Teacher E a letter summarizing a meeting in which they discussed how Teacher E’s gifts to students “especially when they are [given] in private, can easily cause the recipients more anxiety than comfort.” Berrisford cautioned Teacher E that he “should exercise great restraint in the way in which you show your support and respect for any of your students” and that “[y]our congratulations and encouragement should be given in a public place and in such a manner that the motives for doing so are unquestionable.” In 2002, a letter from Upper School Principal William Major warned Teacher E that there had been “several incidents over the past few years, including one this year, in which female students reported feeling uncomfortable as a result of your behavior toward them.” The letter noted that Teacher E had asserted to Major that he “never intended anything improper in [his] actions.” The letter also noted that Teacher E had agreed to see a psychiatrist suggested by the school; Teacher E’s personnel file includes a 2002 invoice for a psychiatric consultation. Teacher E acknowledged to us that he saw a therapist paid for by Trinity after the students had complained, as is documented in his personnel file. Teacher E told us that he recalled conversations with Berrisford, Major, and his department chair after female students complained that he made them feel uncomfortable. Berrisford is deceased. Major confirmed that he spoke to Teacher E

13 after a female student complained that she felt uncomfortable around Teacher E and that she felt that he focused on her too much in class. Teacher E’s department chair recalled that Teacher E engaged in “playful or affectionate” behavior with some female students, including trying to hug them. The department chair did not recall speaking to Teacher E about student complaints about his behavior. F. Teacher F Teacher F taught drama at Trinity from the 1980s through the 2000s. Student 15 described how, when she was a sophomore in the late 2000s, in Teacher F’s class and in the school hallways, Teacher F “would start to touch my arms and shoulders more than other students,” complimented her appearance in ways that made her feel uncomfortable, and touched her hair. She also said that she felt “stalked” and “watched,” and that she confided in her parents that the attention was making her feel uncomfortable. Student 15 then met with Scull (then serving as Acting Headmaster) to report this conduct, and Scull asked her to describe her experience to the outgoing and incoming Upper School Principals, Mark Simpson and Lee Palmer. Student 15 also said, and her mother confirmed, that her parents later spoke with Scull about Student 15’s complaints regarding Teacher F’s conduct, which Scull acknowledged to us. Scull and Student 15 said that Trinity terminated Teacher F after Student 15 and her parents informed Scull what had happened. Teacher F’s personnel file includes documents showing that his employment was terminated for cause at the end of that school year. Documents in the file state that the termination was based on the complaint from Student 15, a recent report of an incident involving a different student, and prior incidents of non-sexual, inappropriate behavior. Simpson, who was leaving Trinity to take a position outside the United States, provided Trinity with an affidavit describing complaints about Teacher F that the school had received. The affidavit states that a student reported to Simpson that another female student in Teacher F’s class “had been singled out by [Teacher F] for inappropriate comments and touching that this complaining student had witnessed” and that the student who had been singled out had confirmed what this other student had reported. The affidavit also states, “Another incident reported in [that same month] was [Teacher F] grabbing hold of a student around the waist and not letting go despite the student’s struggling and trying to free herself from his inappropriate contact. [Teacher F] was observed complimenting the student on her dress and saying you can’t escape me.” Trinity and Teacher F ultimately negotiated a separation agreement pursuant to which Teacher F received, in exchange for a general release, a severance payment, reimbursement for one year’s health insurance payments, his school computer, and a letter of recommendation. The letter of recommendation Trinity prepared did not detail the circumstances of Teacher F’s departure. According to Teacher F’s website, he is working as a theater director and acting coach, including for high school students and teachers.

14 In Teacher F’s letter declining our interview request, he wrote that, “I fully and clearly deny that I engaged in any improper sexual conduct with any student during my … years as a faculty member at Trinity” and that “[n]o student has ever accused me of improper sexual conduct.” He also wrote that “I am aware of a vague allegation that was raised in the context of my termination … but I never received details regarding that allegation, and it was certainly never communicated to me by anyone at Trinity School that the allegation related to improper sexual conduct with a student.” G. Other Former Teachers In addition to the teachers described above, we also received reports from former Trinity students about five other former teachers. Unlike the reports about the former teachers described above, these reports did not come directly from students who reported experiencing sexual misconduct, school records did not corroborate reports we received, or the conduct reported was not as serious as the conduct described earlier in this report. VI. Conclusion We appreciate the cooperation and support that we received from Trinity and members of its school community, especially those former students who made the difficult decision to describe to us sexual misconduct they experienced. We hope that this investigation will be of value to them, to other former students who may have experienced sexual misconduct, to the school, and to the greater Trinity community. With the submission of this report, our investigation has come to a close. We recognize that additional members of the school community may want to come forward with information about incidents of adult sexual misconduct at Trinity. Members of the Trinity community who wish to provide such information may contact the Covington team, at [email protected] or (212) 841-1236, or Head of School John Allman, at [email protected] or (212) 932-6814.

15