Hazen v. Board of Education of City School District

Order, Supreme Court, New York County (Shirley Werner Kornreich, J.), entered December 23, 2008, which denied the petition to expunge certain letters from petitioner’s personnel file, and directed entry of judgment dismissing this proceeding with prejudice, unanimously affirmed, without costs.

The petition was filed on April 16, 2008. Since the administrative actions that form the basis of petitioner’s grievance were the placement of the critical letters in her file, the four-month statute of limitations (CPLR 217) applied as of the date of each such action. The placement of any letters prior…