STATE OF NEW YORK SUPREME COURT i COUNTY OF ERIE JAMIE L. CAMPBELL, Plaintiff, vs VERIFIED COMPLAINT Index No. DENNIS GABRYSZAK; ADAM LOCHER; SHELDON SILVER; NEW YORK STATE ASSEMBLY, and STATE OF NEW YORK Defendants. Plaintiff, Jamie L. Campbell, by her attorneys, the Law Offices of John P. Bartolomei & Associates, John P. Bartolomei, Esq., of Counsel, for her complaint against the Defendants, Dennis Gabryszak, Adam Locher, Sheldon Silver, New York State Assembly, and State of New York, alleges, on personal knowledge as to her - B z actions and upon information and belief as to the actions of others, as follows: PARTIES ‘Niagara Fal 1. Plaintiff, Jamie L. Campbell (“Plaintiff or “Campbell’), is and has been at all times pertinent, a resident of the State of New York. 2. Plaintiff was employed by Defendants Gabryszak, New York State Assembly and State of New York at all times pertinent to this complaint. Law Offices of John P. Bartolomei & Associates 335 Buffalo Avenue 3. Defendant, Dennis Gabryszak is and has been at alll times, a resident of the State of New York and at all times pertinent to this complaint, was a member of the New York State Assembly, representing the 143rd District. — A Defeode gt aa 1 PaSyaatans, ie iL — ee ititeeEEserve as the Speaker of the New York State Assembly. 6. As Speaker, it was and remains Defendant Silver's duty to monitor, supervise, and, if necessary, discipline members of the New York State Assembly for any inappropriate behavior. 7. Defendant, New York State Assembly is an elected body of the New York State government which is established under the New York State Constitution Both Defendants Gabryszak and Silver were members of Defendant Assembly at all times pertinent to this matter. Plaintiff and Defendant Locher were employees of Defendant Assembly at all times pertinent to this matter. 8. Defendant, State of New York is a member of the United States of America. Defendant, New York State Assembly is created under the laws of the Defendant, State of New York. NATURE OF ACTION 9. That causes of action brought by Plaintiff Campbell are as follows: Sexual Discrimination Intentional infliction of Emotional Distress Negligent Infliction of Emotional Distress Discrimination Under State Law Under New York State Executive Law Section 296 e. Discrimination Under State Law Under New York State Executive Law Section 296(7) Civil Assautt Civil Battery Negligent Supervision and Retention Vicarious Liability Prima Facie Tort Retaliation Breach of Contract Defamation Slander and Libel Violation of Statute Disability Discrimination aos posar?. Interference With Right of Privacy r Discrimination Under the New York City Administrative Code Section 8-107(1) s Discrimination Under the New York City Administrative Code Section 87-107(1)(e) ff Constructive Wrongful Discharge aa. Conspiracy to Commit Sexual Discrimination bb. Conspiracy to Commit Intentional infliction of Emotional Distress ce. Conspiracy to Commit Negligent Infliction of Emotional Distress dd. Conspiracy to Commit Discrimination Under State Law Under New York State Executive Law Section 298 ee. Conspiracy to Commit Discrimination Under State Law Under New York State Executive Law Section 296(7) fi. Conspiracy to Commit Assault 99. Conspiracy to Commit Battery hh. Conspiracy to Commit Negligent Supervision and Retention ii, Conspiracy Resulting in Vicarious Liability i. Conspiracy to Commit Prima Facie Tort kk. Conspiracy to Commit Retaliation Hi. Conspiracy to Commit Breach of Contract mm. Conspiracy to Commit Defamation nn. Conspiracy to Commit Slander and Libel! 00. Conspiracy to Commit Violation of Statute pp. Conspiracy to Commit Disability Discrimination aa. Conspiracy to Commit Interference With Right of Privacy tr. Conspiracy to Commit Discrimination Under the New York City Administrative Code Section 8-107(1) ss Conspiracy to Commit Discrimination Under the New York City Administrative Code Section 8-107(1)(e) tt Conspiracy to Commit Constructive Wrongful Discharge aaa. Aiding and Abetting Sexual Discrimination bbb. Aiding and Abetting Intentional Infliction of Emotional Distress { nlp yt thre Banoo aeioenimnaigna! Natrona