The Sanders Firm, P.C. has published the public court filings relating to the Order to Show Cause filed in Headley v. City of New York, et al., Index No. 155228/2025, pending in the Supreme Court of the State of New York, New York County.

The Court signed the Order to Show Cause, established an expedited briefing schedule, and scheduled oral argument for September 8, 2026. The Court also directed that the Order and supporting papers be immediately transmitted to numerous NYPD officials and offices involved in the investigation, prosecution, supervision, and adjudication of the disciplinary proceeding at issue.

Rather than summarize hundreds of pages of sworn affidavits, affirmations, exhibits, and court filings, we believe the public should have the opportunity to review the record directly.

The complete filing package—including the signed Order to Show Cause, supporting affirmations, affidavits, exhibits, and related papers filed on the public docket—is available below.

As with any pending litigation, the allegations contained in the parties’ filings remain subject to judicial determination. The Court has scheduled briefing and oral argument, and no decision has yet been rendered on the merits of the application.

We encourage members of the public, the media, and members of law enforcement to read the filings themselves.

Read the Order To Show Cause

Read the Affidavit of Shatorra Foster

Read the Affirmation of Eric Sanders, Esq. 

Read the Supplemental Affirmation of Eric Sanders, Esq. 

Read Exhibit A Verified Answer With Counterclaims

Read Exhibit B Decision

Read Exhibit C Notice of Entry 

Read Exhibit D Motion for Default 

Read Exhibit E Charges and Specifications 

Read Exhibit F Selected Investigative Worksheets

Read Exhibit G Email to Trial Commissioner Requesting Department Review 

Read Exhibit H Email Complaint to OEI and IAB

Read Exhibit I Email to OEI and IAB Supplemental Complaint 

Read Exhibit J Email to OEI and IAB Second Supplemental Complaint

Read Exhibit K OEI and IAB Complaint Confirmation 

Read Exhibit L Bronx Retaliation Lawsuit Regarding the Investigation

Read Exhibit M Affirmation of Service 

Read Exhibit N Bronx Retaliation Lawsuit Regarding Random Drug Test

Read Exhibit O Affirmation of Service

Read Exhibit P DAO Motion In Limine

Read Exhibit Q Response to DAO Motion in Limine

Read Exhibit R  DCT Trial Room Decision – Trevlyn Headley

Read the Memorandum of Law