RETURN: OCTOBER 12, 2010
CHRISTINE MAISANO, suing on : SUPERIOR COURT
behalf of her minor child Jane Doe, :
and PATRICIA DePALMA, suing on :
behalf of her minor child Sara Doe :
:
VS. : J. D. OF NEW HAVEN
:
NICHOLAS R. PALLADINO, :
RONALD DeNUZZO, :
ANTHONY R. SERIO and :
DOM MILANO : SEPTEMBER 13, 2010
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.
2. The defendants Palladino and DeNuzzo are members of the East
Haven Board of Education. The defendant Serio is the East Haven
Superintendent of Schools. The defendant Milano is a Security Guard at East
Haven High School. All defendants are sued only in their individual capacities.
3. At all times mentioned in this Complaint, the defendants acted jointly
and in concert with each other for the improper and unlawful purposes herein
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described.
4. In June 2010, motivated solely by political differences with Christine
Maisano and Patricia DePalma, the mothers of the victim plaintiffs herein, the
defendants Palladino and DeNuzzo visited the East Haven High School and
attempted to use their powers as members of the East Haven Board of
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
defendants Palladino and DeNuzzo intended to use those records to gain
political advantage over the mothers of the students without regard to any injury
they might thereby inflict upon the children.
5. On or about June 25, 2010, the defendants Palladino, DeNuzzo and
Serio, acting illegally and without authorization of the Board of Education,
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
Attendance Clerk at East Haven High School, to unlawfully disclose confidential
educational information concerning Jane Doe to the aforesaid Dan Markle.
7. On July 1, 2010, the defendant Serio coerced Barbara Loesche, the
Secretary to the Principal of East Haven High School, to unlawfully disclose
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confidential educational information concerning Jane Doe to the aforesaid Dan
Markle.
8. On June 29, 2010, the defendant Serio coerced Michele Madonna, a
Guidance Counselor at East Haven High School, to unlawfully disclose
confidential educational information concerning Jane Doe to the aforesaid Dan
Markle.
9. On August 16, 2010, the defendant Serio coerced Joe Marangell, a
teacher at East Haven High School, to unlawfully disclose confidential
educational information concerning Sara Doe to the aforesaid Dan Markle.
10. On July 1, 2010, the defendant Dom Milano unlawfully disclosed
confidential educational information concerning Jane Doe to the aforesaid Dan
Markle.
11. On August 24, 2010, the defendant Serio, acting under the direction
of and in conspiracy with the defendants Palladino and DeNuzzo, unlawfully
disclosed to the defendants Palladino and DeNuzzo, and unlawfully disclosed to
other members of the East Haven Board of Education, including Thomas S.
Hennessey, Laura L. Kluth, Raymond D. Pompano, Charles V. Scalesse and
Kristen L. Vineyard, a written document prepared by the aforesaid Dan Markle
which recited in detail confidential educational information concerning Jane Doe
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
legitimate interest therein.
12. As a result, the victim plaintiffs Jane Doe and Sara Doe have suffered
emotional distress.
WHEREFORE the plaintiff Christine Maisano claims judgment against the
defendant Palladino for invasion of privacy.
COUNT TWO
1 - 12. Paragraphs 1 through 12 of Count One are hereby made
Paragraphs 1 through 12 of Count Two.
WHEREFORE the plaintiff Christine Maisano claims judgment against the
defendant DeNuzzo for invasion of privacy.
COUNT THREE
1 - 12. Paragraphs 1 through 12 of Count One are hereby made
Paragraphs 1 through 12 of Count Two.
WHEREFORE the plaintiff Christine Maisano claims judgment against the
defendant Serio for invasion of privacy.
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COUNT FOUR
1 - 12. Paragraphs 1 through 12 of Count One are hereby made
Paragraphs 1 through 12 of Count Four.
WHEREFORE the plaintiff Christine Maisano claims judgment against the
defendant Milano for invasion of privacy.
COUNT FIVE
1 - 12. Paragraphs 1 through 12 of Count One are hereby made
Paragraphs 1 through 12 of Count Five.
WHEREFORE the plaintiff Patricia DePalma claims judgment against the
defendant Palladino for invasion of privacy.
COUNT SIX
1 - 12. Paragraphs 1 through 12 of Count One are hereby made
Paragraphs 1 through 12 of Count Six.
WHEREFORE the plaintiff Patricia DePalma claims judgment against the
defendant DeNuzzo for invasion of privacy.
COUNT SEVEN
1 - 12. Paragraphs 1 through 12 of Count One are hereby made
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Paragraphs 1 through 12 of Count Seven.
WHEREFORE the plaintiff Patricia DePalma claims judgment against the
defendant Serio for invasion of privacy.
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.
2. The defendants Palladino and DeNuzzo are members of the East
Haven Board of Education. The defendant Serio is the East Haven
Superintendent of Schools. The defendant Milano is a Security Guard at East
Haven High School. All defendants are sued only in their individual capacities.
3. At all times mentioned in this Complaint, the defendants acted jointly
and in concert with each other for the improper and unlawful purposes herein
described.
4. In June 2010, motivated solely by political differences with Christine
Maisano and Patricia DePalma, the mothers of the victim plaintiffs herein, the
defendants Palladino and DeNuzzo visited the East Haven High School and
attempted to use their powers as members of the East Haven Board of
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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
defendants Palladino and DeNuzzo intended to use those records to gain
political advantage over the mothers of the students without regard to any injury
they might thereby inflict upon the children.
5. On or about June 25, 2010, the defendants Palladino, DeNuzzo and
Serio, acting illegally and without authorization of the Board of Education,
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
Attendance Clerk at East Haven High School, to unlawfully disclose confidential
educational information concerning Jane Doe to the aforesaid Dan Markle.
7. On July 1, 2010, the defendant Serio coerced Barbara Loesche, the
Secretary to the Principal of East Haven High School, to unlawfully disclose
confidential educational information concerning Jane Doe to the aforesaid Dan
Markle.
8. On June 29, 2010, the defendant Serio coerced Michele Madonna, a
Guidance Counselor at East Haven High School, to unlawfully disclose
confidential educational information concerning Jane Doe to the aforesaid Dan
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Markle.
9. On August 16, 2010, the defendant Serio coerced Joe Marangell, a
teacher at East Haven High School, to unlawfully disclose confidential
educational information concerning Sara Doe to the aforesaid Dan Markle.
10. On July 1, 2010, the defendant Serio coerced the defendant Dom
Milano to unlawfully disclose confidential educational information concerning
Jane Doe to the aforesaid Dan Markle.
11. On August 24, 2010, the defendant Serio, acting under the direction
of and in conspiracy with the defendants Palladino and DeNuzzo, unlawfully
disclosed to the defendants Palladino and DeNuzzo, and unlawfully disclosed to
other members of the East Haven Board of Education, including Thomas S.
Hennessey, Laura L. Kluth, Raymond D. Pompano, Charles V. Scalesse and
Kristen L. Vineyard, a written document prepared by the aforesaid Dan Markle
which recited in detail confidential educational information concerning Jane Doe
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
legitimate interest therein.
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
would cause the minor victim plaintiffs to suffer emotional distress.
13. As a result, the victim plaintiffs Jane Doe and Sara Doe have suffered
severe emotional distress.
WHEREFORE the plaintiff Christine Maisano claims judgment against the
defendant Palladino for intentional infliction of emotional distress.
COUNT NINE
1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made
Paragraphs 1 through 13 of Count Nine.
WHEREFORE the plaintiff Christine Maisano claims judgment against the
defendant DeNuzzo for intentional infliction of emotional distress.
COUNT TEN
1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made
Paragraphs 1 through 13 of Count Ten.
WHEREFORE the plaintiff Christine Maisano claims judgment against the
defendant Serio for intentional infliction of emotional distress.
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COUNT ELEVEN
1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made
Paragraphs 1 through 13 of Count Eleven.
WHEREFORE the plaintiff Patricia DePalma claims judgment against the
defendant Palladino for intentional infliction of emotional distress.
COUNT TWELVE
1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made
Paragraphs 1 - 13 of Count Twelve.
WHEREFORE the plaintiff Patricia DePalma claims judgment against the
defendant DeNuzzo for intentional infliction of emotional distress.
COUNT THIRTEEN
1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made
Paragraphs 1 - 13 of Count Thirteen.
WHEREFORE the plaintiff Patricia DePalma claims judgment against the
defendant DeNuzzo for intentional infliction of emotional distress.
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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
[email protected]
Their Attorney
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RETURN: OCTOBER 12, 2010
CHRISTINE MAISANO, suing on : SUPERIOR COURT
behalf of her minor child Jane Doe, :
and PATRICIA DePALMA, suing on :
behalf of her minor child Sara Doe :
:
VS. : J. D. OF NEW HAVEN
:
NICHOLAS R. PALLADINO, :
RONALD DeNUZZO, :
ANTHONY R. SERIO and :
DOM MILANO : SEPTEMBER 13, 2010
PRAYER FOR RELIEF
The plaintiffs claim judgment for compensatory damages and punitive
damages in an amount greater than fifteen thousand dollars ($15,000.00),
exclusive of interest and costs.
THE PLAINTIFFS
BY:________________________________
JOHN R. WILLIAMS (#67962)
51 Elm Street
New Haven, CT 06510
(203) 562-9931
Fax: (203) 776-9494
[email protected]
Their Attorney
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