Beruflich Dokumente
Kultur Dokumente
COMPLAINT
COUNT ONE
1. The plaintiffs are adult citizens of the United States who reside in East
Haven, Connecticut. They bring this action on behalf of their minor children,
herein described as Jane Doe and Sara Doe, to protect their privacy. Jane Doe
and Sara Doe are students in the East Haven Public Schools.
Haven High School. All defendants are sued only in their individual capacities.
and in concert with each other for the improper and unlawful purposes herein
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described.
Maisano and Patricia DePalma, the mothers of the victim plaintiffs herein, the
defendants Palladino and DeNuzzo visited the East Haven High School and
Education to coerce members of the faculty and staff of the school to disclose to
them confidential educational records of Jane Doe and Sara Doe. The
political advantage over the mothers of the students without regard to any injury
ordered the expenditure of public funds to hire a third party, one Dan Markle, to
gain access to the confidential educational records of Jane Doe and Sara Doe to
which neither he nor the defendants Palladino and DeNuzzo were entitled.
6. On June 29, 2010, the defendant Serio coerced Gina Fronte, the
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confidential educational information concerning Jane Doe to the aforesaid Dan
Markle.
Markle.
Markle.
11. On August 24, 2010, the defendant Serio, acting under the direction
and Sara Doe which Markle had illegally obtained from educators employed by
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the East Haven Public Schools. Thereafter, the defendant Palladino maliciously
and unlawfully disclosed the same document to Patricia Cofrancesco and James
Cirillo, neither of whom had any legal right to see the document nor any
12. As a result, the victim plaintiffs Jane Doe and Sara Doe have suffered
emotional distress.
COUNT TWO
COUNT THREE
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COUNT FOUR
COUNT FIVE
COUNT SIX
COUNT SEVEN
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Paragraphs 1 through 12 of Count Seven.
COUNT EIGHT
1. The plaintiffs are adult citizens of the United States who reside in East
Haven, Connecticut. They bring this action on behalf of their minor children,
herein described as Jane Doe and Sara Doe, to protect their privacy. Jane Doe
and Sara Doe are students in the East Haven Public Schools.
Haven High School. All defendants are sued only in their individual capacities.
and in concert with each other for the improper and unlawful purposes herein
described.
Maisano and Patricia DePalma, the mothers of the victim plaintiffs herein, the
defendants Palladino and DeNuzzo visited the East Haven High School and
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Education to coerce members of the faculty and staff of the school to disclose to
them confidential educational records of Jane Doe and Sara Doe. The
political advantage over the mothers of the students without regard to any injury
ordered the expenditure of public funds to hire a third party, one Dan Markle, to
gain access to the confidential educational records of Jane Doe and Sara Doe to
which neither he nor the defendants Palladino and DeNuzzo were entitled.
6. On June 29, 2010, the defendant Serio coerced Gina Fronte, the
Markle.
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Markle.
10. On July 1, 2010, the defendant Serio coerced the defendant Dom
11. On August 24, 2010, the defendant Serio, acting under the direction
and Sara Doe which Markle had illegally obtained from educators employed by
the East Haven Public Schools. Thereafter, the defendant Palladino maliciously
and unlawfully disclosed the same document to Patricia Cofrancesco and James
Cirillo, neither of whom had any legal right to see the document nor any
12. The conduct of the defendants described above was extreme and
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outrageous and was carried out in reckless disregard of the probability that it
13. As a result, the victim plaintiffs Jane Doe and Sara Doe have suffered
COUNT NINE
COUNT TEN
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COUNT ELEVEN
COUNT TWELVE
COUNT THIRTEEN
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THE PLAINTIFFS
BY_______________________________
JOHN R. WILLIAMS (#67962)
51 Elm Street
New Haven, CT 06510
(203) 562-9931
Fax: (203) 776-9494
jrw@johnrwilliams.com
Their Attorney
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RETURN: OCTOBER 12, 2010
THE PLAINTIFFS
BY:________________________________
JOHN R. WILLIAMS (#67962)
51 Elm Street
New Haven, CT 06510
(203) 562-9931
Fax: (203) 776-9494
jrw@johnrwilliams.com
Their Attorney
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