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Case 3:15-cv-01078.-PGS-LHG Document 1 Filed 0
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UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY DONNA MANSFIELD,
ivil Action No.:
Plaintiffs, -against-
OMPLAINT
Plaintiff Demand a Jury Trial
TOMS RIVER BOARD OF EDUCATION and PE
ER BRATTAN
Defendants Plaintiff, DONNA MANSFIELD appearing by her attorneys, AKIN LAW GROUP PLLC as
and for her Complaint against the Defendants, respectfully allege as follows:
PRELIMINARY STATEMENT
I
. The Defendants discriminated against Plaintiff DONNA MANSFIELD based on her sex and
further retaliated against the Plaintiff for complaining about the discrimination.
2.
More specifically, this is an action for monetary damages, for the Defendants' violation of
Plaintiffs rights under Title VII of the Civil Rights Act of 1964 (42 U.S.C. §§2000e-2000e-17
et seq. as amended), regarding unlawful discrimination regarding Plaintiffs sex and for retaliating against the Plaintiff for complaining about said discrimination, in violation of
§704(a) of the Civil Rights Act of 1964, as amended.
3.
In addition, Defendants Discriminated and retaliated against the Plaintiff in further violation of
New Jersey Law Against Discrimination N.J.S.A. 10:5-1 et seq.
 
Case 3:15-cv-01078-PGS-LHG Document 1 Filed 02/10/15 Page 2 of 14 PagelD: 2
JURISDICTION AND VENUE
4.
The jurisdiction of this Court over this controversy is invoked pursuant to 28 U.S.C. §§1331
and 1343, as this action involves federal questions.
5.
The Court has supplemental jurisdiction pursuant to 28 U.S.C. §1367(a) over related claims
brought under the New Jersey Law Against Discrimination and New Jersey State common law.
6.
In addition, this Court is empowered to issue a declaratory judgment pursuant to 28 U.S.C.
§§2201 and 2202.
7.
Plaintiff DONNA MANSFIELD (herein after
Ms.
Mansfield ) duly filed a Charge of
Discrimination (No. 524-2014-00859) with the United States Equal Employment Opportunity Commission.
8.
The
EEOC forwarded the action to the United States Department of Justice and the United
Stated Department of Justice issued Ms. Mansfield a Notice of Right to Sue dated December 14, 2014.
9.
Venue is appropriate under 28 U.S.C. § 1391 (b) and (c) (Substantial Part of the Events and
Contacts), as a substantial part of the acts or omissions giving rise to the claims alleged herein occurred within this judicial district, the Defendants regularly conducts business in this district
and the Defendant is subject to personal jurisdiction in this disti ct.
PAR l IES
10, That at all
the times hereinafter mentioned, the Ms. Mansfield was and still is a resident of the
State of New Jersey, County of Ocean.
11. That at all the times hereinafter mentioned, the Defendant TOMS RIVER BOARD OF
EDUCATION (hereinafter BOE ) was and is an organized board existing by virtue of the
laws of the state of New Jersey.
 
Case 3:15-cv-01078-PGS-LHG Document 1 Filed 02/10/15 Page 3 of 14 PagelD: 3
12.
That at all times hereinafter mentioned, Defendant PEIER BRATTAN (''Brattan ), is an
individual and resident of the State of New Jersey, County of Ocean.
13.
That at all times hereinafter mentioned, Defendant BOE operates out of its offices at 1144
Hooper Avenue Toms River, New Jersey 08753.
14.
That at all times hereinafter mentioned, Defendants BRATTAN is employed at the Defendant
BOE's office located at 1144 Hooper Avenue Toms River, New Jersey 08753.
FACTS
15.
That on or about August 1998, Ms. Mansfield commenced employment with the Defendant
BOE as Manager for Cafe 1144.
16.
That at all times mentioned, Defendant PETER BRATTAN was and is employed as a Food
Service Director with the Defendant BOE.
17.
That at all times mentioned, Defendant PE IER BRATTAN was a senior and/or superior of
Plaintiff with regard to their employment at Defendant BOB.
18.
That at all times mentioned, Defendant PhihR BRATTAN was an agent, servant and or
employee at Defendant BOE.
19.
That at all times mentioned, Defendant PETER BRATTAN was a senior and/or superior of
Plaintiff with regard to their employment at Defendant BOE.
20.
That on or about 2010, the former superintendant of BOE, Mike Ritacco, was brought up on
criminal charges and stepped down from his position.
21.
That at the time, Ms. Mansfield was dating Mike Ritacco.
22.
That after Mike Ritamo stepped down from his position from the BOE, Frank Roselli, the
interim superintendant, directed Ms. Mansfield in for a meeting and told her that she needs to

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