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v. : AT MIDDLETOWN
:
TOWN OF WESTBROOK, NOEL BISHOP:
PAUL CONNELLY, GEORGE PYTLIK :
and CHRISTOPHER EHLERT,
Defendants : December 15, 2010
COMPLAINT
2. On or about November 2007, Jones was elected to a two year term as Town
relevant to this matter, a municipal corporation under the laws of the State of Connecticut.
LICARI , WALSH
& SKLAVER, LLC
105 COURT STREET
NEW HAVEN, CT 06511
------------
(203) 752-1450
FAX (203) 752-1401
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matter the First Selectman for the Town of Westbrook. He is being sued in both his official
6. The defendant, PAUL CONNELLY, (“Connelly”) is and was at all times relevant to
this matter the Chairman of the Board of Finance for the Town of Westbrook. He is being
7. The defendant, GEORGE PYTLIK, (“Pytlik”) is and was at all times relevant to this
matter a member of the Town of Westbrook Board of Finance. He is being sued in both his
relevant to this matter a member of the Board of Finance for the Town of Westbrook. He is
9. Since her election as Town Treasurer, the Defendants have engaged in a systematic
pattern of conduct, both individually and collectively, with the intent of damaging
10. The Defendants have refused plaintiff’s requests for increased hours and additional
staff, while at the same time decreasing plaintiff’s Department Budget and reducing her
staff.
LICARI , WALSH
& SKLAVER, LLC
105 COURT STREET
NEW HAVEN, CT 06511
------------
(203) 752-1450
FAX (203) 752-1401
-------------
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11. In addition, defendants have repeatedly made false and defamatory statements about
12. The defamatory statements have identified plaintiff to third parties and have been
published to those third parties at public meetings of both the Town of Westbrook Board of
13. The statements made by the defendants were false and/or made with reckless
well as private finance has been significantly damaged such that Jones has been unable to
secure full or part time employment within her chosen field of accounting.
1-14. Paragraphs one through fourteen of count one are hereby incorporated by reference and
15. The plaintiff has suffered severe mental and emotional distress due to the defendant’s
actions as well as humiliation, indignity and harm to her reputation as a result of these
actions.
LICARI , WALSH
& SKLAVER, LLC
105 COURT STREET
NEW HAVEN, CT 06511
------------
(203) 752-1450
FAX (203) 752-1401
-------------
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17. The defendant’s knew or should have known that their actions would cause severe
1-14 Paragraphs one through fourteen of count one are hereby incorporated by reference and
15. The defendants knew or should have reasonably foreseen that their conduct as well as
that of their agents involved an unreasonable risk of causing emotional distress and that
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2. Such other and further relief to which the plaintiff is, at law, or in equity and by
statute entitled.
THE PLAINTIFF
BY: ______________________________
John M. Walsh Jr., Esq.
LICARI, WALSH & SKLAVER, LLC
His Attorney
____________________________
John M. Walsh, Jr., Esq.
LICARI , WALSH
& SKLAVER, LLC
105 COURT STREET
NEW HAVEN, CT 06511
------------
(203) 752-1450
FAX (203) 752-1401
-------------