John Halpern, a Bain & Company co-founder, sued for sexual abuse and sexual assault
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Speaker Camer Mut Shar En
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FILED: NEW YORK COUNTY CLERK 11/22/2023 08:06 PM INDEX NO. 952327/2023 
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SUPREME COURT OF THE STATE OF NEW YORK 
COUNTY OF NEW YORK
X
CHRISTOPHER MICHAEL AUSNIT,
I
n
d
-against- eSUMMONS
x
 Venue based on 
JOHN DALE HALPERN, NCPLR § 503(a):
oSitus of Events
Defendant. .Jury Trial 
:Demanded
Plaintiff, X
SIR/MADAM:
YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy 
of your Answer on the undersigned attorneys for Plaintiff, AIDALA, BERTUNA & KAMINS 
P.C., at 546 5th Avenue, New York, New York, 10036, within twenty (20) days after the service 
of this Summons and Complaint, exclusive of the day of service, or within thirty (30) days after 
the service is complete, if this Summons is not personally delivered to you within the State of 
New York. In the case of your failure to answer, judgment will be taken against you by default 
for the relief demanded in the complaint, together with the costs of this action.
AIDALA, BERTUNA & KAMINS, P.C.
BY:
IMRAN H. ANSARI, ESQ.
ROSARIO BONA, ESQ.
Attorneys for Plaintiff
546 5th Avenue, 6th Floor 
New York, New York
(212) 486-0011
[email protected] 
[email protected]
TO:
JOHN DALE HALPERN
250 Pendleton Avenue
Palm Beach, Florida 33480
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SUPREME COURT OF THE STATE OF NEW YORK 
COUNTY OF NEW YORK
X
CHRISTOPHER MICHAEL AUSNIT,
Plaintiff, Index No.:
-against-
VERIFIED COMPLAINT
JOHN DALE HALPERN, Venue based on 
CPLR § 503(a):
Defendant. Situs of Events
Jury Trial 
Demanded
X
Plaintiff, CHRISTOPHER MICHAEL AUSNIT, by and through his attorneys, 
Aidala, Bertuna & Kamins P.C., files this VERIFIED COMPLAINT against Defendant JOHN 
DALE HALPERN, and alleges upon knowledge concerning his own acts and upon information 
and belief as to all other matters, as follows:
NATURE OF ACTION
1.Plaintiff  Christopher Michael  Ausnit  (hereinafter  “Plaintiff”)  was 
sexually assaulted and abused by Defendant John Dale Halpern (hereinafter “Defendant”) 
multiple times during an extensive and extenuating period of time, ranging between 
1972 and 1994, approximately. The abuse was systematic, repetitive, horrific, outrageous, and 
spanned from when the Plaintiff was a minor, to adulthood, causing extensive psychological 
trauma and emotional distress.
2. This action is brought pursuant to the New York Adult Survivors Act, CPLR § 
214-
j.1 The conduct at issue constituted sexual offense(s) in violation of a section within Article 130 of
1 CPLR § 214-j recites as follows: “Certain sexual offense actions. Notwithstanding any provision of 
law which imposes a period of limitation to the contrary and the provisions of any other law pertaining 
to the filing of a notice of claim or a notice of intention to file a claim as a condition precedent to 
commencement
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the New York Penal Law,2 and resulted in physical, psychological, and emotional injuries. As a
civil cause of action was previously time-barred prior to August 14, 2019, the Adult Survivors 
Act, CPLR § 214-j, revives the claims set forth below.
3.This action is timely because it falls within the above-mentioned CPLR § 214-j 
and is brought during the one-year time period set forth in that section. The claims brought 
herein allege intentional acts for physical, psychological, and other injury suffered as a 
direct and proximate result of conduct that would constitute sexual offenses as defined in Article 
130 of the New York Penal Law, and such acts were committed against Plaintiff also when he 
was eighteen years of age or older.
4.Specifically, the conduct that gives rise to Plaintiff’s claims herein are 
Defendant’s violations of the New York Penal Law (hereinafter “P.L.”), including but not 
limited to, P.L. §
130.20 (sexual misconduct), P.L. § 130.52 (forcible touching), P.L. § 130.80 (course of sexual 
conduct against a child in the second degree), and P.L. § 130.91 (sexually motivated felony), all 
constituting a sexual offense as defined in Article 130 of the New York Penal Law.
PARTIES AND JURISDICTION
5.At all times material hereinafter mentioned, Plaintiff was a resident of New 
York County, New York. Plaintiff is now a resident of Florida.
of an action or special proceeding, every civil claim or cause of action brought against any party 
alleging intentional or negligent acts or omissions by a person for physical, psychological, or other 
injury or condition suffered as a result of conduct which would constitute a sexual offense as defined in 
article one hundred thirty of the penal law committed against such person who was eighteen years of age 
or older, or incest as defined in section 255.26 or 255.27 of the penal law committed against such 
person who was eighteen years of age or older, which is barred as of the effective date of this section 
because the applicable period of limitation has expired, and/or the plaintiff previously failed to file a 
notice of claim or a notice of intention to file a claim, is hereby revived, and action thereon may be 
commenced not earlier than six months after, and not later than one year and six months after the 
effective date of this section. In any such claim or action, dismissal of a previous action, ordered before 
the effective date of this section, on grounds that such previous action was time barred, and/or for failure 
of a party to file a notice of claim or a notice of intention to file a claim, shall not be grounds for 
dismissal of a revival action pursuant to this section.” 2 For further reference, please see NY CLS Penal, 
Pt. Three, Title H, Art. 130.
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6. At all times material hereinafter mentioned, Defendant was a resident of either
Massachusetts or Florida. Defendant currently resides in Palm Beach, Florida
7.Plaintiff is a 56-year-old actor, and he was born and raised in the City and State 
of New York.
8.Defendant is a 76-year-old private equity investment manager, and at all 
relevant time periods herein, was either residing or present in the States of Connecticut, 
Florida, Massachusetts, New York, and New Hampshire.
9. Defendant is Plaintiff’s maternal uncle.
10.At all times material hereinafter mentioned, Defendant was an individual liable 
to the Plaintiff and subject to this Court’s jurisdiction.
11. This Court has jurisdiction over this matter pursuant to CPLR § 301.
12.Venue is proper pursuant to CPLR § 503(a) because a substantial part of the 
events giving rise to the within claims occurred in New York County.
FACTUAL ALLEGATIONS COMMON TO ALL COUNTS
13.Plaintiff, as detailed herein, was subjected to repeated sexual and 
emotional harassment and abusive behavior by Defendant, causing Plaintiff to suffer significant 
stress, pain, suffering, embarrassment, and physical as well as mental anguish.
14.Plaintiff was born on February 22, 1967, at New York Hospital. He was raised 
in Manhattan in his grandfather and father’s building – 525 Park Avenue. Plaintiff attended 
the Dalton School First Program, Buckley School, and then Saint David’s School from first to 
eighth grade. Plaintiff continued at St. Ann’s School, went to college for two years at Vassar, and 
finished his undergraduate studies at Columbia.
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15. Despite Plaintiff's education in prestigious institutions and upbringing in affluent
New York City neighborhoods, his childhood and adolescence were characterized by numerous 
instances of significant mistreatment inflicted by Defendant, his maternal uncle.
16.Defendant developed a recurring pattern of sexual and violent abuse of 
Plaintiff since his youngest age, exploiting the control he had over him. Plaintiff’s mother 
failed to intervene, and in fact condoned, if not encouraged, the Defendant’s behavior.
17.Defendant used his power, influence, and authority, to physically and 
sexually assault Plaintiff multiple times.
18.Plaintiff’s earliest memories of the beating and sexual abuses he was suffering 
from Defendant date back to when he was attending second and third grade. Plaintiff could hardly 
sleep at night and often wet his bed for the anxiety and fear he was subjected to.
19.Defendant masturbated in front of Plaintiff and attempted to forcibly 
masturbate Plaintiff several times. Every time he had the chance, Defendant attempted to 
assault Plaintiff, forcefully trying to touch Plaintiff’s intimate parts, and trying to make Plaintiff 
touch Defendant’s intimate parts.
20.Defendant’s modus operandi has always been outrageous and violent. 
Defendant beat, hit, and kicked Plaintiff, and then would touch, or attempt to touch, Plaintiff’s 
genitals against Plaintiff’s will. Despite his limited strength and understandable shock, Plaintiff 
always tried to fight back, run away, and to hide somewhere to avoid Defendant’s anger and 
despicable sexually deviant actions. Defendant also used to get into bed with Plaintiff several 
times to sexually abuse him. If Plaintiff did not comply with Defendant’s sexual advances, 
Defendant would beat Plaintiff with a shoe or a brush.
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21. This pattern of abuse has evolved and occurred in several Halpern family home
locations, including properties located in New Hampshire, Massachusetts, Connecticut, Florida, 
and New York. The despicable and terrible actions Plaintiff had to suffer occurred mainly in 
Manhattan, but also in East Hampton, New York. Such abuse occurred well over thirty times.
22.In or around 1973, while in Boston with Defendant, Defendant abused Plaintiff 
and touched his genitals, causing Plaintiff to break into tears. After that occurred, Defendant 
violently screamed at Plaintiff “Stop crying! Do not let anyone see you crying!” as he feared 
that his neighbor – Tom O’Neil – could witness what was happening. In many other occasions, 
Defendant yelled at Plaintiff that he had embarrassed him by crying in front of his neighbor.
23.Defendant also spent time alone with Plaintiff in a vacation home in 
New Hampshire. At least ten times, Defendant molested, abused, and hit Plaintiff in this house.
24.In or around 1979, Plaintiff’s mother and her husband decided to divorce. At 
the age of twelve, Plaintiff provided testimony during his parents’ divorce and asked Judge 
Hortense Gabel not to live with his mother anymore and to be emancipated, to escape his uncle, 
and abusive household.
25.During the divorce proceedings, Plaintiff was assigned an appointed 
child psychiatrist, to whom Plaintiff shared his traumatized observations of Defendant’s 
genitals. Plaintiff also reported this to the Court.
26.During the divorce proceedings, Plaintiff was also assigned guardian ad litem 
to whom Plaintiff also revealed the nature of Defendant’s abuse in detail.
27.At the end of ninth grade, Plaintiff’s mother tried to send Plaintiff to a 
residential school for criminal offenders because of the testimony and revelations Plaintiff 
provided during the divorce proceedings.
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28. Around 4 months later, Plaintiff felt compelled to run away and go live with his
father. Some weeks later, Plaintiff’s father left New York for business purposes and Plaintiff’s 
mother brought him back to her home.
29.Plaintiff’s father petitioned the Court handling the divorce proceedings for 
custody of Plaintiff. Eventually, however, Plaintiff’s mother obtained custody and child 
support. After Plaintiff repeated how he did not want to live with his mother based on the history 
of past abuse, the Judge allowed Plaintiff to live by himself, while the mother could still receive 
the child support money to pay for Plaintiff’s necessary expenses. Plaintiff was given an 
apartment at 525 Park Avenue, a building owned by his father.
30.In or around 1982, Plaintiff’s maternal aunt moved in the same building and, 
after the divorce proceedings were over, Plaintiff started to live with his aunt, as Plaintiff’s father 
was constantly traveling for business and eventually moved to Los Angeles. The divorce 
Judge endorsed this.
31.While living with his aunt at 525 Park Avenue, and after Plaintiff turned 
eighteen years old, Defendant abused Plaintiff several times.
32.Plaintiff tried to have a guardian ad litem remove him from his aunt’s 
oversight several times. The aunt was furious about those attempts and several times called 
Defendant to come over the apartment and “discipline” or intimidate Plaintiff through physical 
violence.
33.Defendant used to arrive in the apartment, hide or ambush somewhere, and 
scare Plaintiff by suddenly grabbing him from behind. Defendant would grab Plaintiff by his 
throat and penis. Defendant also used to twist Plaintiff’s arm and would violently squeeze and 
twist Plaintiff’s penis while berating him.
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34. Plaintiff often had no other choice than running away and hiding or leaving the
apartment. However, when Plaintiff attempted to resist, Defendant used to react with anger and hit 
Plaintiff to scare him and attempt to dominate him. Defendant used to firmly put his hands on 
Plaintiff’s mouth and try to choke him. These violent episodes occurred at 525 Park Avenue 
more than twenty times.
35.Plaintiff also used to complain about Defendant’s conduct to his grandmother, 
who lived in an apartment at the Ritz Tower, in Manhattan.
36.Around ten times and when Plaintiff was over the age of eighteen, Defendant 
would encounter Plaintiff in his grandmother’s apartment and would engage in the same 
violent and abusive pattern. In or around 1986, for instance, Defendant struck Plaintiff in his 
face at his grandmother’s apartment and Plaintiff ended up with a bloody lip.
37.Plaintiff’s mother also had a house in Georgica Close Road, East Hampton, 
New York. Plaintiff would go stay in this house periodically as his mother was often not there.
38.Around ten times during the period between 1985 and 1990, when Plaintiff 
was over the age of eighteen, Defendant came to the house in East Hampton and intimidated him 
with threats of violence and punishment. These episodes would often end up with Defendant 
hitting Plaintiff and once again grabbing Plaintiff’s genitals without consent.
39.During the aforementioned timeframe when Plaintiff was above the age of 
eighteen, Defendant purposefully initiated a disturbing pattern of ambushing, assaulting, and 
forcefully seizing Plaintiff's genitals, reminiscent of prior abuses during his younger years. This 
reprehensible behavior was intended to intimidate Plaintiff and exert psychological control over 
him.
40.In or around the year 1994, Plaintiff felt compelled to evade the 
violent environment he was continually exposed to and decided to move to Los Angeles, 
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41. In the period between 1985 and 1995, Plaintiff regularly met with a child
psychiatrist and obtained counseling for his post-traumatic stress disorder, emotional distress, 
depression, and his problems sleeping at night. Moreover, after moving to Los Angeles, California, 
Plaintiff regularly met a doctor for counseling from 2008 to 2013.
42.The factual contentions outlined above are corroborated by at the minimum 
two individuals who provided statements attesting to their awareness of Plaintiff’s outcry and 
history of trauma and sexual abuse. See statements attached hereto as EXHIBIT A and 
EXHIBIT B. Furthermore, Plaintiff talked about these deplorable abuse at the hands of the 
Defendant to many other friends and acquaintances at or around the time of the events, or in the 
years thereafter.
43.Upon information and belief, Defendant has engaged in the same or similar 
pattern of conduct and has sexually assaulted and molested other individuals.
44.The occurrence of similar facts at the detriment of different individuals 
over considerably disparate time periods illustrates and highlights Defendant's predisposition to 
assault others, underscoring the imperative need for justice to prevail.
45.As a direct and proximate result of Defendant’s conduct described herein, 
Plaintiff has suffered and will continue to suffer, great pain of mind and body, severe and 
permanent emotional distress, physical manifestations of emotional distress, embarrassment, loss 
of self-esteem, humiliation, depression, physical, personal, and psychological injuries.
46.As a direct and proximate result of Defendant’s conduct described herein, 
Plaintiff was prevented, and will continue to be prevented from performing normal daily 
activities and obtaining the full enjoyment of life. Indeed, Plaintiff sustained social 
disruption, adjustment problems, and a loss of confidence in his ability to develop social and 
intimate relationships.
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Plaintiff has no familial relations, life partner, or progeny, is still traumatized, and his life is 
heavily
affected by the experiences he suffered at Defendant’s hands.
47.As a direct and proximate result of Defendant’s conduct described herein, 
Plaintiff felt extremely humiliated, degraded, victimized, embarrassed, emotionally distressed, 
extremely distraught, and intimidated. Therefore, Plaintiff sustained severe emotional trauma, 
depression, illness, hopelessness and anxiety, and other irreparable harm resulting from the 
pattern of violent and sexual abuse pursued by Defendant and other family members. As a 
consequence, Plaintiff has incurred and will continue to incur expenses for psychological 
treatment, therapy, and counseling, and, on information and belief, has and/or will incur loss 
of income and/or loss of earning capacity.
48.As a result of the Defendant’s intolerable and outrageous treatment of Plaintiff, 
he has suffered the physical and psychological ailments detailed above.
49.As a result of the above, Plaintiff has been damaged in an amount which 
exceeds the jurisdiction limits of all lower Courts.
50.As Defendant’s conduct has been malicious, willful, outrageous, and 
conducted with full knowledge of the law, Plaintiff respectfully demands Punitive Damages 
as against Defendant.
COUNT I 
SEXUAL ASSAULT
51.Plaintiff re-alleges and incorporates by reference each and every allegation in 
the previous paragraphs as though fully set forth herein.
52.As described above, Defendant violently, forcibly, and against Plaintiff’s will 
and without his consent, frightened and placed him in apprehension of harm when he 
inflicted unwanted sexually oriented touching and other offensive physical contact.
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53. As described above, Defendant committed sexual assault against Plaintiff because
he intentionally placed Plaintiff in apprehension of harm by engaging in unpermitted, unlawful, 
intentional, and offensive touching of sexual nature or application of force to Plaintiff’s person.
54.In fact, Defendant forcibly touched the sexual or other intimate parts of Plaintiff 
for the purpose of degrading or abusing Plaintiff, or for the purpose of gratifying Defendant’s 
sexual desire.
55.As a direct and proximate result of Defendant’s conduct, Plaintiff has 
suffered physical and psychological injuries, severe emotional distress, humiliation, 
embarrassment, anxiety, loss of enjoyment of life, extreme emotional trauma, and other 
consequential damages.
56.Defendant’s conduct described above was willful, wanton, and malicious. At 
all relevant times, Defendant acted with conscious disregard of Plaintiff’s consent, rights, 
and feelings.
57.Defendant acted with knowledge of or with reckless disregard for the fact that 
his conduct was certain to cause injury and/or humiliation to Plaintiff, and intended to cause 
fear, physical injury, and/or pain and suffering to Plaintiff.
58.By virtue of the foregoing, Plaintiff is entitled to recover compensatory 
damages, together with punitive and exemplary damages from Defendant according to proof at 
trial.
COUNT II 
SEXUAL BATTERY
59. Plaintiff re-alleges and incorporates by 
reference each and every allegation in the
previous paragraphs as though fully set forth herein.
60.As described above, Defendant violently, forcibly, and against Plaintiff’s will 
and without his consent, subjected him to bodily harm when he inflicted unwanted sexually 
oriented touching and other offensive physical contact.
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61. As described above, Defendant committed sexual battery against Plaintiff because
he intentionally engaged in unpermitted, unlawful, intentional, and offensive touching of sexual 
nature or application of force to Plaintiff’s person.
62.In fact, Defendant forcibly touched the sexual or other intimate parts of Plaintiff 
for the purpose of degrading or abusing Plaintiff, or for the purpose of gratifying Defendant’s 
sexual desire.
63.As a direct and proximate result of Defendant’s conduct, Plaintiff has 
suffered physical and psychological injuries, severe emotional distress, humiliation, 
embarrassment, anxiety, loss of enjoyment of life, extreme emotional trauma, and other 
consequential damages.
64.Defendant’s conduct described above was willful, wanton, and malicious. At 
all relevant times, Defendant acted with conscious disregard of Plaintiff’s consent, rights, 
and feelings.
65.Defendant acted with knowledge of or with reckless disregard for the fact that 
his conduct was certain to cause injury and/or humiliation to Plaintiff, and intended to cause 
fear, physical injury, and/or pain and suffering to Plaintiff.
66.By virtue of the foregoing, Plaintiff is entitled to recover compensatory 
damages, together with punitive and exemplary damages from Defendant according to proof at 
trial.
COUNT III
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
67.Plaintiff re-alleges and incorporates by reference each and every allegation in 
the previous paragraphs as though fully set forth herein.
68.Defendants engaged in extreme and outrageous conduct and beyond the 
bounds of decency tolerated in civilized society toward Plaintiff.
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69. Defendants intended to cause or disregarded a substantial probability of causing
severe emotional distress to Plaintiff.
70. There exists a causal connection between the above conduct and said injury.
71.As a direct and proximate result of said conduct Plaintiff suffered and suffers 
from severe emotional distress including problems sleeping, anxiety, neurological problems, 
post-traumatic stress disorder, and other ailments.
72.Defendant’s conduct described above was willful, wanton, and malicious. At 
all relevant times, Defendant acted with conscious disregard of Plaintiff’s consent, rights, 
and feelings.
73.Defendant acted with knowledge of or with reckless disregard for the fact that 
his conduct was certain to cause injury and/or humiliation to Plaintiff, and intended to cause 
fear, physical injury, and/or pain and suffering to Plaintiff.
74.By virtue of the foregoing, Plaintiff is entitled to recover compensatory 
damages, together with punitive and exemplary damages from Defendant according to proof at 
trial.
PRAYER FOR RELIEF
WHEREFORE, based on the foregoing causes of action, Plaintiff prays for judgment 
against Defendant in an amount that will fully and fairly compensate Plaintiff for Plaintiff’s 
injuries and damages and for any other relief the Court deems appropriate. The amount of 
damages sought in this Complaint exceeds the jurisdictional limits of all lower courts 
which would otherwise have jurisdiction, including but not limited to:
a. a declaratory judgment that the actions, conduct and practices of Defendant 
complained of herein violate the laws of the State of New York and the City of 
New York;
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b. a money judgment representing compensatory damages including consequential
damages, lost wages, earning, and all other sums of money, together with interest 
on these amounts, according to proof;
c. an award of money judgment for mental pain and anguish and severe emotional 
distress, according to proof;
d. punitive and exemplary damages according to proof;
e. equitable damages and/or relief;
f. attorneys’ fees and costs with appropriate enhancement;
g. pre-judgment interest and post-judgment interest; and
h.such other relief as may be available and which this Court deems to be fair, 
just, and equitable.
JURY DEMAND
Plaintiff demands a trial by jury on all issues so triable.
DATED: November 22, 2023
New York, New York
Respectfully submitted,
AIDALA, BERTUNA & KAMINS P.C.
By:
IMRAN H. ANSARI, 
ESQ.
ROSARIO BONA, ESQ.
Attorneys for Plaintiff
546 5th Avenue, 6th Floor 
New York, New York
(212) 486-0011
[email protected] 
[email protected]
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ATTORNEY' S VERIFICATION
IMRAN H. ANSARI, an attorney admitted to practice in the Courts of New York State, 
affirms the following to be true under the penalties of perjury: I am an attorney at AIDALA 
BERTUNA & KAMINS, P.C., attorneys of record for Plaintiff, CHRISTOPHER MICHAEL 
AUSNIT. I have read the foregoing VERIFIED COMPLAINT and know the contents thereof; the 
same is true to my own knowledge, except as to the matters I believe to be true. The reason this 
verification is made by me and not by my client, is that my client is not presently in the County 
where I maintain my offices. The grounds of my belief as to all matters not stated upon my own 
knowledge are the materials in my file and the investigation conducted by my office.
DATED: November 22, 2023
New York, New York
Respectfully submitted,
AIDALA, BERTUNA & KAMINS P.C.
By:
IMRAN H. ANSARI, ESQ.
Attorneys for Plaintiff
546 5th Avenue, 6th Floor 
New York, New York
(212) 486-0011
[email protected]
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