PART III. SEXUAL ABUSE OF CHILDREN, FORCED NUDITY, INVASIVE SEARCHES, PHOTOGRAPHS OF NAKED MINORS — AND LAW ENFORCEMENT ALLEGEDLY RETURNING CHILDREN TO THEIR ABUSERS
The thirty federal lawsuits describe an institution in which children allegedly endured sexual assault, forced nudity, invasive bodily searches, sexual humiliation, and the systematic suppression of complaints.
Some plaintiffs identify particular employees who allegedly sexually assaulted them.
Others describe being stripped naked and photographed by adults upon arrival, before receiving any medical examination or therapeutic services.
Several allege that the institution maintained collections of student intake photographs and supplied photographs to local law enforcement for identifying and returning children who escaped.
Still others describe reporting abuse to police and being returned to the institution.
The most disturbing question for Delaware County is whether its law-enforcement institutions knowingly helped return children to a place where sexual exploitation and abuse were occurring.
The federal complaints do not establish that Delaware County officials personally committed the sexual assaults. They do, however, allege institutional knowledge, suppression of complaints, affirmative law-enforcement assistance, and governmental protection of the enterprise.
I. A fifteen-year-old girl alleges sexual assault by six adult men during intake
In C.R. v. Education Plus Corporation, No. 6:26-cv-01409, filed July 21, 2026, the plaintiff describes an extraordinarily disturbing intake procedure.
According to paragraphs 14, 34, and 74 of her verified complaint, six adult male employees subjected her to a forced strip search when she arrived at FFS at age fifteen.
She alleges that the men surrounded her, required her to undress, denied her privacy, dragged her from a bathroom stall while naked, and forced her to squat and cough.
The complaint further alleges that she was digitally penetrated during the procedure.
The six employees are named as John Does 1–6.
C.R. attributes the institutional intake policy to FFS management and cites testimony from Paul Geer's federal criminal proceedings concerning the school's strip-search practices.
A fifteen-year-old girl alleges that her introduction to a purported therapeutic institution was a sexual assault by six adult men.
The allegations concern conduct by FFS personnel, not identified County deputies.
But they raise an urgent question about what County authorities knew concerning the institution's treatment of newly admitted children.
II. A fifteen-year-old boy allegedly forcibly stripped and photographed by five adult employees
In Stephen Sullivan v. Education Plus Corporation, No. 3:26-cv-01849, filed September 28, 2026, the plaintiff describes another intake incident.
According to paragraphs 18 and 48–50, Sullivan refused to undress when instructed.
He alleges that at least five adult male employees physically overpowered him, removed his clothing, and photographed him.
The complaint describes institutional books containing intake photographs of students, including photographs of unclothed minors.
Sullivan further alleges that student intake photographs were supplied to Hancock police and the Delaware County Sheriff's Office to facilitate the identification and recovery of escaping children.
The complaint does not establish that photographs depicting nudity were among those supplied to law enforcement.
Nevertheless, the allegations identify two potentially connected institutional practices: forced nude photography and the use of student photographs in runaway recovery.
What photographs did law enforcement receive, and did County officers know how those photographs had been obtained?
III. Children allegedly stripped and photographed as a routine institutional practice
In Tell v. Education Plus Corporation, No. 3:26-cv-02087, filed October 8, 2026, John Tell alleges that adult male employees required him to undress, inspected his naked body, and photographed him with a Polaroid camera.
In Haham v. Education Plus Corporation, No. 3:26-cv-01735, filed September 14, 2026, Daniella Haham alleges that other confined students conducted her intake strip search under staff direction.
In Dellinger v. Education Plus Corporation, No. 3:26-cv-01767, filed September 17, 2026, Alex Dellinger alleges that staff photographed him after an intake strip search and before he was permitted to dress.
In Adam Bellows v. Education Plus Corporation, No. 3:26-cv-01784, filed September 21, 2026, the plaintiff describes being thrown against a locker and subjected to a forced strip search in the presence of older students.
In Sarah Sullivan v. Education Plus Corporation, No. 3:26-cv-01842, filed September 28, 2026, the complaint describes institutional practices involving strip searches and the maintenance of intake photographs.
The recurrence of these accounts across different plaintiffs and enrollment periods supports the plaintiffs' contention that the searches were institutional practices rather than isolated incidents.
The complaints allege that children were subjected to these procedures without legitimate medical justification and under circumstances intended to establish submission to institutional authority.
IV. The photographs — what did Delaware County law enforcement receive?
Several federal complaints allege that FFS maintained student intake photographs and provided photographs to local law enforcement for use in locating and returning escaping children.
The allegations identify Hancock police and the Delaware County Sheriff's Office.
In Candito v. Education Plus Corporation, No. 3:26-cv-01817, filed September 23, 2026, paragraphs 49–50 describe the alleged maintenance and distribution of student photographs.
In Stephen Sullivan, paragraphs 48–50 describe the intake photography practice and alleged law-enforcement use of student photographs.
In C.R., the complaint also describes institutional photography and alleged cooperation with law enforcement in recovering runaways.
The unanswered question is whether photographs obtained through forced nude searches were ever supplied to, possessed by, or reviewed by County law enforcement.
The complaints establish allegations that nude photographs were taken and that intake photographs were used for runaway recovery. They do not establish that the particular photographs supplied to police depicted children naked.
That distinction makes disclosure of the underlying records essential.
Where are the intake photograph books?
What images were provided to the Sheriff's Office?
Who received them?
Were copies maintained in County files?
Were the photographs used in missing-person reports, police bulletins, or apprehension records?
And what did law-enforcement personnel know about the circumstances in which the images had been created?
V. Sexual exploitation by an assigned institutional sponsor
In C.R., paragraphs 17, 31, and 76–77, the plaintiff alleges that her assigned sponsor, Debbi Knack, sexually exploited her while exercising disciplinary authority over her.
The complaint describes a coercive feeding regime in which C.R. was allegedly required to eat food that caused vomiting and then consume her vomit.
Knack allegedly used her authority to relieve the child of those punishments in exchange for sexual acts.
C.R. further alleges that access to off-campus trips was conditioned upon submission to sexual abuse.
The allegations describe sexual exploitation enforced through control over food, punishment, movement, and institutional privileges.
The alleged abuser did not need to physically imprison the child in a separate location. The institution's disciplinary structure allegedly supplied the coercion.
This is particularly consequential because the plaintiff was a minor entrusted to the institution for care and treatment.
VI. A sixteen-year-old allegedly sexually assaulted by his family-unit leader — then beaten with a chain after escaping
In Verbin v. Education Plus Corporation, No. 3:26-cv-02095, filed October 12, 2026, plaintiff Jordan Lee Verbin identifies his assigned family-unit leader as Tom Wood, known as "Woody."
Verbin alleges that Wood sexually touched him when he was sixteen.
He further alleges that after he escaped from FFS, Wood pursued him by automobile through the Catskill Mountains, beat him with a chain, forced him into the vehicle, and returned him to the institution.
This account combines alleged sexual abuse with violent recapture by the same adult exercising institutional authority.
A child allegedly escaped from an employee who had sexually abused him, only to be pursued, beaten, and forcibly returned to the institution.
The alleged recapture was performed by Wood, not an identified County officer.
But the incident illustrates the danger that could arise when escaping children were returned without independent investigation of their reasons for leaving.
VII. Paul Geer — the criminal conviction and the alleged institutional concealment
Unlike the allegations against many other defendants, the criminal misconduct associated with former FFS employee Paul Geer has been adjudicated.
Geer was convicted in federal criminal proceedings in 2025 and sentenced to twenty-seven years in prison for offenses involving sexual misconduct connected with FFS students.
Multiple civil complaints allege that institutional administrators knew of prior complaints concerning Geer and nevertheless retained him.
In Van Arsdale v. Education Plus Corporation, No. 3:26-cv-01462, filed June 29, 2026, the plaintiff describes sexual abuse and institutional practices during her enrollment.
In Baldwin v. Education Plus Corporation, No. 3:26-cv-02076, the plaintiff alleges that she was housed in the basement of Geer's residence despite the institution's alleged prior knowledge of misconduct.
In S.H. v. Education Plus Corporation, No. 3:26-cv-01412, filed July 21, 2026, the complaint discusses the institution's handling of abuse reports and cites testimony concerning the absence of a reliable system for investigating complaints.
In Verbin, the plaintiff alleges that he personally witnessed Geer sexually touching younger students.
The conviction does not establish the liability of Delaware County, its Sheriff's Office, or Board of Supervisors.
But it makes the allegations of suppressed complaints and failures to investigate particularly serious.
What did County authorities know about sexual-abuse complaints concerning FFS employees, and when did they know it?
VIII. Sexual humiliation as an institutional disciplinary practice
The complaints also describe systematic sexualized humiliation.
Children allegedly were required to disclose intimate sexual information publicly, describe masturbation habits, and endure accusations concerning sexual conduct before groups of students and staff.
In Tell, the plaintiff alleges that adult employees compelled him to describe and demonstrate, over his clothing, how he masturbated.
In Barley v. Education Plus Corporation, No. 3:26-cv-01493, filed August 3, 2026, the plaintiff describes repeated accusations of sexual deviance and compelled disclosure of intimate information.
In J.K. v. Education Plus Corporation, No. 3:26-cv-01780, filed September 18, 2026, the plaintiff alleges that Geer publicly humiliated children during choir rehearsals with accusations concerning masturbation and sexual behavior.
In Sarah Sullivan, the plaintiff describes gender-targeted humiliation, including having her hair cut off as punishment.
These accounts describe an alleged disciplinary culture in which adults used sexual shame to exercise control over children.
The plaintiffs contend that such practices were not legitimate therapy but coercive humiliation.
IX. Suppressing sexual-abuse complaints
Several complaints allege that FFS maintained no effective system for documenting, investigating, or reporting abuse complaints.
In S.H., paragraph 69, the plaintiff cites testimony attributed to Susan Runge concerning her inability to account for the total number of complaints received or identify a reliable review procedure.
In Van Arsdale, paragraph 66, the plaintiff alleges that students attempted to report abuse to FFS administrators, Hancock police, the Delaware County Sheriff's Office, and medical providers, but that complaints were suppressed.
In Jane Doe, paragraph 83, the plaintiff alleges that complaints made to institutional administrators, law enforcement, and medical providers were suppressed, with students threatened or returned to FFS.
The complaints further allege that the Argiros family deliberately destroyed institutional records, including student files and abuse complaints, around the institution's closure.
Some of those allegations refer to testimony in Geer's federal criminal trial.
The alleged concealment was not confined to keeping children silent. It extended to the destruction of records that could have documented what children reported.
X. Law enforcement allegedly returned children after reports of abuse
This is the most serious connection between the sexual-abuse allegations and Delaware County governmental institutions.
In Dellinger, paragraph 50, the plaintiff alleges that he personally reported abuse to Hancock police after escaping FFS.
He was returned without investigation.
In Baldwin, paragraph 63, the plaintiff alleges that she personally observed police returning escaping children to the institution.
In Van Arsdale, the complaint alleges that the Sheriff's Office received abuse reports, suppressed complaints, and returned escaping students without investigation.
In C.R., the plaintiff alleges that County law-enforcement institutions participated in recovering escaping students despite reports of institutional misconduct.
The complaints do not establish that every child returned by police had reported sexual assault or that every return was performed by a Delaware County deputy.
But they identify an alleged practice requiring examination of law-enforcement records and individual incidents.
Were children who reported sexual abuse returned to the custody of the institution where the alleged perpetrators remained in positions of authority?
Were their allegations recorded?
Were child protective authorities contacted?
Were the children interviewed outside the presence of institutional personnel?
Were the alleged perpetrators investigated?
And did any County official authorize returns despite knowledge of sexual-abuse complaints?
XI. The allegation of governmental protection in exchange for political and financial benefits
The allegations become more serious when considered alongside the claims of reciprocal governmental protection.
In S.H., paragraph 103, Van Arsdale, paragraph 112, Cowan-Johnson, paragraph 112, and C.R., paragraph 131, the plaintiffs allege that the Delaware County Sheriff's Office and Board of Supervisors received financial and political benefits from the Argiros family's countywide economic influence in exchange for institutional protection.
These are allegations, not adjudicated findings of bribery or corruption.
Nevertheless, they raise a fundamental question concerning the independence of public law enforcement.
Did County institutions fail to investigate allegations of child sexual abuse because of the political and economic influence of the institution's owners?
And did any governmental institution affirmatively help return children to an enterprise that was allegedly sexually exploiting them?
The plaintiffs' allegations, if substantiated, would implicate not merely the conduct of private abusers but the integrity of public institutions entrusted with investigating crimes against children.
XII. Federal case inventory — sexual abuse, forced nudity, photography, and alleged law-enforcement involvement
The following cases contain particularly relevant allegations discussed in this section.
| Federal case | Case number | Principal allegations |
|---|---|---|
| C.R. v. Education Plus Corp. | 6:26-cv-01409 | Invasive intake search, alleged sexual assault by staff, sponsor exploitation, law-enforcement recovery practices |
| Stephen Sullivan v. Education Plus Corp. | 3:26-cv-01849 | Forced stripping and photography by adult staff, institutional photograph books |
| Sarah Sullivan v. Education Plus Corp. | 3:26-cv-01842 | Intake practices, sexualized humiliation, institutional control |
| Tell v. Education Plus Corp. | 3:26-cv-02087 | Forced nude photography, compelled sexual disclosures |
| Haham v. Education Plus Corp. | 3:26-cv-01735 | Student-administered strip searches under staff direction |
| Dellinger v. Education Plus Corp. | 3:26-cv-01767 | Intake photography, firsthand abuse report to Hancock police followed by return |
| Bellows v. Education Plus Corp. | 3:26-cv-01784 | Forced intake strip search and attempted photography |
| Verbin v. Education Plus Corp. | 3:26-cv-02095 | Alleged sexual assault by family-unit leader, violent recapture |
| Van Arsdale v. Education Plus Corp. | 3:26-cv-01462 | Sexual abuse, suppressed complaints, County institutional knowledge |
| Baldwin v. Education Plus Corp. | 3:26-cv-02076 | Police returning children, alleged prior institutional knowledge concerning Geer |
| S.H. v. Education Plus Corp. | 3:26-cv-01412 | Failure to investigate abuse complaints, alleged County protection |
| Barley v. Education Plus Corp. | 3:26-cv-01493 | Sexual humiliation and coercive institutional practices |
| J.K. v. Education Plus Corp. | 3:26-cv-01780 | Sexualized humiliation, coercive discipline |
| Candito v. Education Plus Corp. | 3:26-cv-01817 | Student intake photographs allegedly provided to law enforcement |
| Jane Doe v. Education Plus Corp. | 3:26-cv-01397 | Suppressed complaints, institutional concealment, County law-enforcement allegations |
| Cowan-Johnson v. Education Plus Corp. | 6:26-cv-01560 | County institutional notice and alleged protection of the enterprise |
XIII. Questions Delaware County must answer before November 3, 2026
What photographs of children were supplied to the Delaware County Sheriff's Office?
Did County law enforcement receive or possess photographs of unclothed minors taken during forced institutional searches?
What complaints concerning sexual assault or exploitation at FFS were received by the Sheriff's Office?
Were those complaints investigated, referred to child protective authorities, or suppressed?
How many children reporting abuse were apprehended and returned to FFS by County personnel?
Were any children returned to the custody of employees they had accused of sexually abusing them?
What did County authorities know about complaints concerning Paul Geer and other FFS employees?
What records were created concerning the institution's intake procedures, disciplinary practices, and treatment of escaping children?
Did any County official intervene to discourage investigations or protect the institution from scrutiny?
What financial or political benefits, if any, were exchanged between County institutions and the Argiros family's businesses or associated organizations?
And did those relationships influence the County's response to allegations of sexual exploitation of children?
The federal complaints do not establish the County's liability. But they describe serious abuse allegations and identify specific law-enforcement practices and records requiring public scrutiny.
The most damaging accusation is not simply that children were sexually abused at FFS. It is that public law enforcement allegedly helped preserve the institution's control over children despite complaints of abuse, while County governmental bodies allegedly benefited from protecting the enterprise.
If substantiated, that would represent a profound breach of public trust.
Delaware County voters deserve an accounting before November 3, 2026.
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