SUPII.

ENIE COUITT THE STATE NEW YORK OF OF C O U N T Y FJ E F F E R S O N O

KITYS'Ir\L G RICE, Plaintill. -againstJ E F F E R S O NC O U N T Y S H E R I F F ' SO F F I C E . { a municipalentity, JOHN P. BURNS,individually' and in his capacityas Sheritf of the JellersonCounty Sherifl'sOflice, NIICHAEL PETERSON,individuallyancl in his capacityas Lieutenant the of Jell'erson County Sherill's Olfice, STEVEN COTE, individuallyand irr h i s capacityas Detective the Jell'erson of County Sheritf'sOffice,jointly and severally, Delendants.

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Date Index No. Purchased:

TO THEABOVENAMEDDEFENDANTS: JEFFERSON COUNTYSHERIFF'S OFFTCE, SHERTFF JOHN P,BURNS, MICHAEL LT. PETERSON, DET.STEVENCOTE, all rvitholliceslocated 753WatermanDrive,lVatertorvl, at NY 13601 Youarehereby summoned ansrver complaint thisaction to serve copyofyour to the in and a answer, if thecomplaint notserved or, is with thissummons, serye notice appearance, the to. a of on Plaintiffs attorney within20 daysafter service thissummons, the of exclusive (or ofthe dayofservice within30 daysaftertheservice con.rpletethissummons notpersonally is if is delivcred youwithin to tlie State ofNew York);andin case judgment betaken ofyour lailure appear answer, to or lvill .rgainst you by def'ault thereliefdemanded theconrolaint. for in
T h e b a s i s f v e n u p s G P L R3 0 1 ,r v h i c h s t h el o c a t i o n f t h c o c c u r r e n c c f t h e c v c n t sa n d o i i o o incidents alleged theConrplaint. in .: /). J t ' ' , t ' 1t / r , , (lr / ('-"} Dated: Februa+,yJ 2012 +, L-L{.r-(r-i, /( Sackets Harbor. NY ChanrNarerng, Esc1. r/ 472 Bracly Rcl. S a c k c tF l a r b o r . Y 1 3 6 8 5 s N Plronc:616.23L9500

SUPREMB COURTOF THE STATEOF NEW YORK COUNTYOF JEFFERSON KRYSTAL G RICE, Plaintiff,
-againstJEFFERSON COUNTY SHERIFF'S OFFICE, a municipal entity, JOHN P. BURNS,individually and in his capacityas Sheriff of the JeffersonCounty Sheriffs Office, MICHAEL PETERSON, individually and in his capacityas Lieutenant of the Jefferson County Sheriffs Office, STEVEN COTE, individually and in his capacityas Detectiveof the JeffersonCounty Sheriff s Office,jointly and severally Defendants.

'<f"/A InrlexNo.:
VERIFIED COMPLAINT

- /13

JURY TRIAL DEMANDED

Plaintiff,by and throughher attorney, CharuNarang,EsQ., herebycomplains the of Defbndants follows: as NATURE OF ACTION 1. PlaintiffKrystalG. Rice (hereinafter "Rice") bringsthis actionfor defamation, breach of fiduciaryduty and intentional inflictionof emotional distress against Defendants Steven "Cote"), MichaelPeterson Cote(hereinafter (hereinafter "Peterson"), JohnBurns (hereinafler "Burns") and the Jefferson CountySherilfs Department (hereinafter "JCSO" or "JCSD") to recoverdamages a resultof the actionsand/orinactions the as of defbndants.

2' Plaintiffhasbeen. sincethe day of heremployrnent the JCSO, fbrmerlyknownasthe by Jeffbrson CountySheriff'sDepartment, subjected exploitative to behavior and derisive andhostilecomments defendants thosein its ernploy.Specifically, by and Def-endant Coterepresented Plaintiffthe official needfor photographing in various to her states of undress an investigation onlinepedophiles, for of and,then,proceeded takeher to to remotelocation'alone,and photograph in little or no clothing. This action her was authorized Defendant by Peterson. Defendants executed written Contract a (hereinafter "Contract")with Plaintiffregarding useof the photos, the and stated that the Contract and the photos, which wereto be storedon a t'loppyDisk (hereinafter "Disk") would be kept one a

together Defbndant in Cote's possession. Defendants represented plaintiff that no to would haveaccess the Disk otherthanDefendant to Coteand Plaintiff,and

that plaintiff sheasked.

couldhavethe only copy of the Disk containing photosback at any time her

WhenPlaintiffaskedfor the disk, Defendants stated that they could not produce When it. Plaintiffaskedfor a copy of the Contract, Defendants could not produceit. plaintiff has no recourse against Def-endants any otherpartyfbr unauthorized or viewing and/or

dissemination Plaintiffs photosr,vithout Disk and Contract.plaintiff of the hasno idea who may or may not haveviewedor disseminated photos. her
J.
1

Furthermore, Defendant Cotehasengaged a pattern sexualharassment in of and defamation against Plaintiffsincethe time of thephotosession.

: 1 . Specifrcally, Detbndant Cotemadestatements Plaintiff's to boyfiiend's motherregarding hervirtue,all of r'vhich wereuntrue andfalse, resulting Plaintiffbeingridiculed in by thirdparties and the endingof Plaintilfsrelarionship with her boyfiiend.

5. The above hascaused act Plaintiffcxtreme emotional distress humiliation. and 6. In addition, Def-endant did relayandcause Cote third parties disseminate to falserumors aboutPlaintiffand herpersonal life. which havecaused Plaintiffextreme emotional distress humiliation. and 7. PlaintitT bringsthis actionto recoverfbr the extensive emotional damage hassuffered she asa resultof the defendants actions. 8. Plaintiffattempted resolve to this matterprior to commencing actionby servinga this Noticeof Claim uponthe Jeflbrson County Attorney's Officeon March l5 ,2012. 9. Sincethattime, therehasbeenno contact communication or from the CountvAttornev's Ofl-rce regarding Plaintiffs claim 10.At present, morethan 30 dayshaveelapsed sincethe service the Notice of Claim upon of the Countyand the filing of this Complaint.

PARTIES
I l. PlaintiffRice an employee the JCSOwith an officeaddress 753 Waterman is of of Drive, Watertown,, 13601 NY . 12.Defendant JCSOis a government entityin Jefferson CountyNY with an ofl-rce address of 753 Waterman Drive,Watertown, NY 13601. 13.Defendant Burnsis an individual employed JCSO. by l'1.Defendant Peterson an individual is employed the JCSo. by 15.Defbndant cote is an individual employed rheJCSo. by

JURISDICTION AND VENUE 16.This Courthasjurisdiction overthismatter pursuant CPLR Section to 301,because of all the parties this actionareresidents this County. to of 17. This Courtis the propervenuefbr thisproceeding pursuant CPLR Section , to 301 because of the actionscomplained hereinoccurred this County. all of in FACTS 18.On or aboutJanuary 2005,Plaintiffbegan internship an with the thenJefferson County Sheriff'sDepartment (hereinafler "JCSD") as partof her degree requirements her for studies SUNY Canton. at 19.At the time Plaintiffbeganher internship, Plaintiff was22yearsold and was a seniorat SLNY Cantonpursuinga bachelors CriminalInvestigations. in 20. Plaintiffdesired careerin law enforcement an internship a and with the JCSDwasan idealway to explorethe f-reld policework. of 21. Duringher internship, Plaintiffhadan opportunity meetnumerous to members the of JCSDand get a flrst-hand look into the innerworkingsof the JCSD. 22.In addition, Plaintiffcompleted hundred six hoursof l'ridealongs"duringthis internship period. 23. Plaintiffflrst met Def'endants Burns,Peterson Coteduring her internship. and 24. On or aboutFebruary 2005,Plaintitftook the Civil Service Examination qualityfbr to employment with the JCSD. 25. Plaintiffscored 95 on this examination wasrank 27't'onthe list of qualitied a and ed applicants.

26. On or aboutMuy 2005,Plaintiffgraduated with honors tiom SUNY Cantonwith a bachelor's degree CriminalInvestigations in 27. On or aboutNovember 2005,Plaintiff received letterfrom the JCSDstating a thatshe wasa "reachable" "eligible"candidate employment and tbr with the JCSD,andthatif shewishedto pursue career a with the JCSD,sheshouldcontactthe JCSD fbr an interview. 28. Subsequently, Plaintiffinterviewed with Defendant Burns,Defendant Jobson and Defendant Peterson. 29. On or aboutDecember 2,2005,Plaintiffreceived letterfrom JCSDindicating a thatshe needed takeand passa physicalexamination orddrto be furtherconsidered a to in for positionwith the JCSD. Attached hereto Exhibit I is a true and accurate as copy of the Decemb 2,2005 letterreceived Plaintifffrom the JCSD. er by 30. On or aboutJanuary 10,2006, Plaintiffwasswornin as a DeputySheriffwiththe JCSD. Attached hereto E,xhibit is a copyof a January as 2 6,2006letterreceived Plaintiff by from JCSDindicating dateof her appointment. the 3 I . On or aboutJanuary17,200fl Plaintiffentered David Sullivan- St. Lawrence the CountyLaw Enfbrcement Academy(hereinafter "Academy")as a cadetfor hereNew York StateBasicCoursefor PoliceOfficerstraining. Attachedheretoas Exhibit 3 is a copyof Plaintifl'sCertificate Completion the BasicCourse PoliceOfficers of of for at theAcademylrom January - May 19,2006. 19

32. On or aboutMay 19,2006,Plaintiffgraduated the top of her classfiom theAcaclemy. at Attached hereto Exhibit4 is a copyof the plaque as py received PlaintifT graduation at from theAcademyindicatingthat shegraduated the top of her class. at 33. Subsequently, in May 2006,began field training also her with the.ICSD, whichwasto lastfbr a periodof twelver.veeks. 34. Plaintiffwasone of two femalerecruits beginning field trainingin May 2006. 35. The otherfemale recruitwas Danielle "Pryce"). Pryce(hereinafter 36. On or aboutJuly 2006,while Plaintiffwas still a Recruit,Defendant Cotewas at his desk andaskedPlaintiffto comeover and speak him. to 37. At that time, Defendant Cotetold Plaintiffthat he had-been authorized by "administration" conductinvestigations the tleld of internetsex crimesin orderto to in catchonlinesexualpredators. 38. Defendant CoteinfbrmedPlaintitTthat was maintaining onlineprofile as a l5 year he an old girl andthat he needed pictures sendto predators they requested to if them. 39. Specifically, Def-endant Coterequested Plaintiffposefbr photographs the online that for sexualpredator investigation Defendant that Cote\,vas conducting. 40. Defendant Coteagainreassured Plaintiffthatthis investigation authorized the was by JCSD,specifically, the "administration." that DeputyPrycehad already by and posedfor suchphotos, that he "needed"morephotos. but 41. Defendant Coteshowed Plaintiffa picture another of fbmaleDeputythathadalready participated this investigation, orderto illustrate sortsof photos in in the thatwould be

takenandthe type of clothingand look that Plaintiffwould be expected havetbr the to photosession. 42.In thepicture shownto Plaintiffby Def'endant Cote,Prycewaswearingcutoffjeanshorts andhalter/tank styletop. Prycewasstanding facingaway from the camera with her legs apart and bentover slightlyat the hips. 43. Plaintiffbelieved that this was the sortof picturethat would be takenof her for the investigation. 44' Plaintiffbelieved that "administration" comprised Defendant was of Burns,Defendant Jobson and Defendant Peterson. 45. Defendant Cote stated thatthey had drafteda Contracf DeputyPryce,which shehad for executed, outlinedthe termsto which Plaintiffwould be agreeing detailwith and in reference the Contract to 46. At that time, Plaintiff informedDefendant Cotethat sheneeded discuss matterwith to the her husband to think it over. and 47. Based Defendant on Cote'sstatements reassurances, afterdiscussing matter and and the with her husband, Plaintiffdecided participate the investigation. to in 48. A few daysafterPlaintiff'sinitial conversation with Defendant Cote,Plaintiffmet with him at the officesof the JCSDto reviewand execute Contractand to haveher photos the takenfbr the investigation. : 49. PlaintifT readand signedthe Contract thatday in the presence Def-endant of Cote. 50. This signing the Contract of wasdonein the otllce space shared Detective by Scott Sterling, who tvaspresent the ofllce thatday. in

5 I . Plaintiffwas infbrmedby Det'endant Cotethat the photoswould be takenwith a camera andthentransf-erred a 3112" floppy disk. to 52. Plaintiffwasassured Defbndant by Cotethat the originalContractthat sheexecuted that day would staywith the Disk and that the Disk would remainin Defendant Cote's possession. 53. To the bestof Plaintiffs recollection, these termswere in the Contract. 54. Plaintiffwasassured Defendant by Cotethat he would secure Disk in his deskin a the lockeddrawer, which he had the only key. to 55. To the bestof Plaintiffs recollection, these termswerein the Contract. 56. In addition, Plaintiffwas assured Defendant by Cotethat he would not removethe Disk from the officesof the JCSD. 57. To the bestof Plaintiffls recollection, these termswerein the Contract. 58. Furthermore, Plaintiffwas assured Defendant by Cotethat prior to using anyof the photoson the Disk, he would contact Plaintiffand receiveher authorization anv the for suchuse. 59. To the bestof Plaintiffs recollection, these termswerein the written Contract. 60. Plaintiffwas assured both Defendants by CoteandPeterson a copy of the Contract that would be put in Plaintiff'spersonnel file. 61. Plaintiffwas assured both Def-endants and Peterson no copiesof the Disk by Cote that would be made. 62. To the bestof Plaintif recollection, f's these terms\,vere the 'uvritten in Contract.

63. Plaintiffwasassured Defendant by Cotethatno othermembers the staffor of administration JCSDwould be allowed view the pictures Plaintiff. of to of 64. To the bestof Plaintiffs recollection, these termswerein the Contract. 65. Plaintiffwasassured both Defendants by CoteandPetersonthat sheeverrequestedthat if the Disk be returned her,, to that shervouldreceive without any ramifications it or problems. 66. To the bestof Plaintiffs recollection, these termswere in the Contract. 67. After signingthe Contract, Defendant CoteaskedPlaintiff if shewas readyto "go". 68. WhenPlaintilf inquiredwherethey weregoing,Defbndant Coterepliedit rvasto takethe photos. 69. Prior to that moment,no one had informedPlaintiffthat the photo session was to take placeout of the oftlcesof the JCSD. 70. Plaintiffbelieved that Defendant Peterson authorized had Defendant Coteto takePlaintiff out of the officesof the JCSD for the photosession. 7l . Based the prior assurances Defendants on of Coteand Peterson regarding photosand the her beliefthat Defendant Peterson awareof andauthorizing of the actions was all of Defendant Cote,Plaintiffwent thatday with Def'endant Cote,in his department issued vehicle, BlackRiver Bay Fishing to Access Site(hereinafter "Site") in the Town of Flounsfield, to takethe photos NY r,vhich wereto be usedin the investigation. ' 12.'I'he Siteis a state wateraccess is in a secluded run and area. 73. PlaintifTis a nativeof the Watcrtown. area. not NY

74. Def-endant awareof the fact that Plaintiffwas unt'amiliar was with the area.because it wasa known fact that Plaintifris a nativeof Massena, Ny. 75. At the time of the photosession, Sitewaswholly unfamiliar location the in and geography Plaintiff-. to 76.In orderto getto the location the photosession, of Detbndant Cotehadto drivedown a hill to an openareawhich allowedfbr the wateraccess. 77. Plaintifldid not seeany otherpeopleat this area. 78. The main roadwas not viewablefrom this area. 79. No passersby would havebeenableto seePlaintiffand Def'endant Cote. 80. Defendant Cotedid not bring any otherf'emale officerS the photo shoot. to 81. Plaintiffand Defendant Coterverenot met by any otherfemalepoliceofficersat the location the photoshoot. of 82. Defendant CotedrovePlaintiffto this locationandaskedher to exit the vehicle. 83. Plaintiffwore a bluemid thigh lengthtieredskirt with a dark coloredpaisleyprint tank top with spaghetti straps. 84. Defendant CoteaskedPlaintiffto posefor the photosin varioussexuallyprovocative ways. 85. Defendant Coteuseda JCSDissued digitalcamera the photosession. for 86. Specifically, Defendant Coteasked Plaintifftolift her skirt to expose thigh,and,for a her separate shot,to expose thongstyleunderwear. her 87. Def-endant took multipleshots Plaintiffin this pose. Cote of

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88. Defendant Cotethenasked Plaintiffremove top andcoverherself her with her hands only. 89. Plaintifldidnot feelcomfbrtable with this manner posing, of and felt thatthis typeof photowas not what sheagreed when shesignedthe Contract. to 90. However, dueto the fact that Plaintiffwas a Recruitand Def'endant Cotewas an experienced ofl-rcer. agreed, she because believed she Defendant Cote was an experienced officerandknew the typesof pictures "needed" catcha pedophile. he to 9l . Defendant Cotetook multipleshotsof Plaintiffin this pose. 92.Defendant CoteaskedPlaintiffto poseoverthe enginecompartment the car while of topless. 93. Plaintiffdid as Defendant asked, was uncomfortable but with the request. 94. Defendant Cotetook multipleshotsof Plaintiffin this pose. 95. 'fhe photosession lastedlrom one half hour to forty five minutes.

96. After the end of the photo session, Defendant CotedrovePlaintiffback to the JCSD building. 97. Defendant Cotedid not exchange wordsr,vith any Plaintiffduringthe returntrip from the photosession. 98. Plaintiffreviewed photosat the offices, the and,thenwent home. 99. At thattime, Plaintif believed f that Defbndant Cotewould call her if he rvanted useanv to of the photos. 100. PlaintifTwent homeafierbeingdropped ofrat the JCSD.

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101 .

lJponarrivingltome,Plaintiff husband s inquired Plaintiffaboutthe photo of

session. shetold him w,hat and hadoccurred. 102. Plaintiffshusband became very angrywith Plaintifffor allowingDef-endant Cote

to takephotos her in waysthatwerenot discussed of priorto the photosession. 103. Plaintiffls husband was very concerned Plaintiffhad beentakenadvantage that of

andthat shehad not beenprovideda copy of the Contract bring homeprior to the to photosession. 104. Plaintiffinformedher husband thatthe Contract would be rvith the photosand

thata copy of the Contract would be in her personnel file. 105. Plaintiffreassured husband her that the Contract shesignedprotected from her

unauthor izeduse misuse the photos, or of andthat shecould get the disk with the photos backat any time. 106. Plaintiffs husband stated that as long as Plaintifffelt shewas protected, would he

not makean issue of this. out 107 . At somepoint in time, Defendant CoteaskedPlaintiffto authorize of one of use

thephotos. 108. 109. I 10. PlaintifT went to the ofl-rce rventto Defbndant and Coters desk. Defendant Cotehad thephotos Plaintiffon his screen. of Plaintifl. not seeDefendant did Coteremovethe disk from a lockedor seclrre

drawer. 1I 1. Plaintif did not know how longthe photos f hadbeenon Def-endant Cote's screen

priorto herarrival.

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I12.

It was a regularwork day and Det-endant Cote's deskwas in a shared office space

with four otherDetectives. 113. Defendant Cote's ofllce space thattime wasa "thoroughfare", at meaning that

manyemployees usedto usethat space a shortcut to navigate as throughthe office. 114. 115. I16. I17. The potentialfor unauthorized individuals view photosof Plaintiffwas high. to Defendant Cotedid not seem concerned aboutthis. Therewasno log documenting viewingof the disk andby whom. the Plaintiffviewedthe photosthat Defendant Cotewantedto useand authorized one

of them. I 18. Plaintiffstill believed was authorizing of the photo for an investigation, she use

andcould get the disk with the photosbackrvhenever askedfor it. she 119. Plaintiffexecuted writtenrelease (hereinafter a "Release") the pictureto be for

usedby Defendant Cote in his investigation. 120, Plaintiffwasassured Defendant by Cotethata copy of the Release would be

placed Plaintiffspersonnel in file. 121. Plaintiffdid not hearanythingmoreaboutthe pictureshehad authorized how and

it was usedand whetherits useresulted an arrest in 122. Subsequent the photosession until March 2009,Defendant to and Coterepeatedly

andcontinuously sexuallyharassed defamed Defendant. and the 123. ': Specifically, duringa trvodaytime periodsometime September 2008or early

October 2008,Plaintiffreceived several text messages her personal phonefiom to cell someone usingYahoomessenser.

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I21.

The content these of messages of the nature "l want you", "when canwe was of

meetup" and"l missyou". 125. 126. 127 . Plaintiffdid not know the sender repeatedly and "who is this" asked Plaintiffdid not receive response herqueries. a to At the time Plaintiffreceived these messages, wasin Massena at the home she NY

of her parents, beingcomforted her family over the dissolution her marriage. by of 128. Plaintiffwas distraught, also,overthe rumorsthat had beencirculated bv

Defendant Coteregarding break-up her marriage the of andthe reasons her divorce. for 129. Plaintiff drove back to Watertown, NY from Massena and went to the officesof

JCSDfor someunrelated reason. 130. Prior to exitingher car to enterthe offices,the sender the textsrevealed of himself

to PlaintifT Def'endant as Cote. l3 1. As shewas navigating offlce,Plaintiffpassed the throughthe Detectives some for

reason, shenoticedthat Defendant and Cotewas in that oftlce,but did not speak him. to 132. Plaintiffhad left her phonein the car,andwhen shereturned her car,Plaintiff to

notedthat therewereseveral moretext messages her phonefrom Defendant on Cote stating that "it was nice to seeyou walk away" and otherphysicalreferences. 133. Plaintiffbecame uncomfortable with the textsfrom Defendant Cote and reminded

him thathe was marriedandthat Plaintiffrespected wife. his 134. Subsequently, Def'endant CotesentPlaintilfa text stating Plaintiffshouldnot tell

anyone thathe was contacting in this manner, her because Def-endant Cote'swifb had

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connections the PSB and that shewas veryjealous,but that Det-endant to Cote fbund Plaintiffvery attractive and he hadto "watchhimself.'around-Plaintifl. 135. 136. Plaintiffshared natureof these the textswith several colleagues her family. and Plaintiff colleagues s advisecl not to pursue her anything against Defbndant Coteif

themessages stopped. 137. Plaintiffleft the text messages unreported until March 2009,, which time at

Plaintiffreceived phonecall from a manwith whom shewas havinga relationship, a and he informedher that Def-endant Cotehadtold his motherthat Plaintiff was "a whore, she's sleptr,vith half the department if your sonhashad any sort of sexualcontact and with her you needto tell him that he needs havehim tested." to 138. Plaintiffsthenboyfriendinformedher ttratpefendantCote alsostated his to

motherthat Plaintitf"went to another memberof department's housewhen he wasnot homeand was nakedin his bed uponhis arrivalhome." 139. Plaintiffis not now or was thena promiscuous person, and when shewas

informedby her boytiiencl aboutDefendant Cote'sstatements her boyfriend's to mother, Plaintiffcontacted Detective Pustizzi,lJnion President eet adviseabouthow to deal to with the situation with Defendant Cote. 140. Based Llpon Pustizzi's recommendation, Plaintiffreported incidentto Sgt. the

Cullen,her directsupervisor, infbrm him that shewould be contacting to Def-endant

'a

Peterson makea fbrmal complaint to against Def-endant Cote for the defamatory statement.

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141.

Subsequently, PlaintifTmet with Det-endants BurnsandPeterson cliscuss to the

defamatory comments and the sexual harassment directed towardher by Defendant Cote. 142. Plaintiffstated Defendants to Burnsand Peterson shehad tried to stopthe that

harassment Defendant by Coteat the groundlevel,as shehad beentaughtin sexual harassment training,, that Def'endant but Cote had nor,v startedto defameher. 143. Defendants Burnsand Peterson assured Plaintiffthat her complaintwould be fully

investigated. 144. Approximately two r.veeks later,Def'endant Peterson with Plaintiffand told met

her that he had lookedinto Plaintiffls complaint against Def'endant Coteand that a Letter of Reprimand would be placedin Defendant Cote'sfile, and that Plaintiffneednot pursue any otheravenues complaintand/orrecourse of against Defendant Coteor the Department. 145. Defendant Peterson askedPlaintiffto write a Statement regarding Defendant

Cote's actions towardsher so that it, too, couldbe placedin both Plaintiff and Defendant Cote's files. 146. Plaintiffcompliedwith Defendant Peterson's request,, believingthat he had

thoroughly investigated complaint. her 147 . Believingthat therewas inadequate follow throughby the JCSDwith regard to

the behavior Def'endant of Cote,Plaintitfdesired havethe disk with her photoswhich to was in the possession Defendant of Cotereturned her. to 148. On or aboutFebruary 26,2009,Plaintiffrequested Defbndant Peterson provide

herwith the disk. At thattime.Detbndant Peterson he would "look into it." said

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149.

On or aboutMarch23,2009,PlaintifTwas informedin person Defendant by

Peterson "Stevedestroyed disk so you havenothingto-worryabout." that the 150. 151. At this point,Plaintitfburstinto tears andlefl Defbndant Peterson's ofllce. Plaintiffdid not question Def-endant Peterson's statements that time, dueto the at

factthat Plaintiffwasstill dealingwith the department's refusalto disciplineDefendant Cotefor his sexually harassing behavior towardsand def'amatory comments about Plaintifl and,furthermore, Plaintiffwas goingthroughthe breakup of her marriage . 152. Between monthsof Marchto May 2010,afier an unrelated the disputewith

Detective Gary Belch (hereinafter "Belch"), Plaintiffwas cornered the women'slocker in room by Detective (hereinafter "Goodman"). Judy Goodman 153. While Plaintiffwas composing herselfafterthe disputewith Belch,Goodman

proceeded lecturePlaintiff,uninvited, to aboutthe "way thingswere". 154. Goodman told Plaintiffthat Plaintiffcouldnot change things,and that because

Plaintiffhad"run upstairs" complainaboutDefendant to Cote'sbehavior towardsher,no onein the Detective's offltce liked Plaintitfor wantedto work with her. 155. Goodman urtherstated Plaintiffthat Plaintiffcould not "cry to administration f to

to fix everylittle thing that goeswrong." 156. When Plaintiffquestioned Goodman abouthow shewould feel if Defendant Cote

sexually harassed Goodman her, repliedthat "he stands over my deskall the time and triesto look down my shirt. I just leanbackso he can't." 157. Goodrnan turtherstated Plaintiffthat"it is a goodold boysclub andnothingis to

goingto change.[f you wantto stnyherefor25 years, you'regoingto needthickerskin."

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158. 159.

Plaintitfwas appalled disgusted Goodman's and by statements her. to On or aboutJanuary 6,2012,PlaintifT learned thatDef_endant may be retiring Cote

in the Summer 2012. of 160. Concerned afterDef-endant that Cote'sretirement, may not be ableto she

ascertain how and when the disk wasdestroyed, January on 9,2012, Plaintiffonceagain requested disk and a copy of the Contract the from Detbndant Peterson. 161. Shewastold not to write an officialmemoandto wait until Friday, January l3th,

to wait and seewhat he could "dig up." 162. 13,h. 163. On JanuaryI Bth 4:57 PM, Plaintiffreceived phonecall from Defendant at a Plaintiffdid not receive any communication from Defendant Peterson January on

Peterson askingthat shemeetwith him at 9 AM on January l9th. 164, Defendant Peterson informed Plaintiffonor aboutJanuary l8,2012,thatno

topless photosof the Plaintiff shouldhavebeentakenby anyone, aloneDefbndant let Cote. 165. On January l9'l', Plaintiffwastold by Defendant Peterson the Contract that could

not be foundand that the disk hadbeendestroyed Defendant by Cote. 166. No one in the JCSO"administration" infbrmedPlaintiffthat Defendant Cotewas

not supposed havetakenPlaintiffs photoshimselfwith or without the presence to of another femaleotficer.

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167.

No onein the.ICSO "administration" informed Plaintilfthat Defendant Cote

shouldnot havetakenPlaintitfout of the ofllcesof the JCSOtg takethe photos of Plaintif f. 168. Plaintiffonly learned that Defendant Cote's actions regarding photosession the

werebeyondthe boundsof any known policy within the JCSOon or aboutJanuary 8tl' I to lgtl'. olz. 2 169. At thattime, Def-endant Peterson stated thathe would makeDefendant Cote

providePlaintifT with an Affidavit stating circumstances datesof the destruction the and of the disk, so that Plaintiffcould be assured pictures her were not usedin any that of unauthorized fashion. 170. Plaintiffstated Defendant to Peterson shedid not trust Defendant that Coteor

anyone that department far as this issuewas concerned. in as 17l. 172. Defendant Peterson responded Plaintiff'sstatements that "hurt my feelings." Defendant Peterson asserted he had alwaysdoneall he could to assist that

Plaintiffin her career. 173. On or aboutJanuary 27tt',, Plaintitfspoketo Detective Pust izzi inconnection with

an unrelated matter. 174. 175. Detective Pustizziis the localUnion President Council 82. for Detective Pustizzi told Plaintiffat thattirnethatDefcndant Cotehadtold him that

pictures Plaintifffrom the photosession existon his work laptop, of did andthathe, Defendant Cote,had stated thathe couldnot erase pictures. those

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176.

Detective Pr,rstizzi infbrmedPlaintiffthatDef'endant Cote had stated that the disk

hadbeendestroyed. 177. Detective Pustizzi alsotold Plaintiffthathe hadheard thatJCSOhadconfiscated

Defendant Cote'sgun and computer andthat if the pictures could not be erased, the computer would be destroyed. 178. On or aboutJanuary 1't.Defendant 3 Peterson calledPlaintiffinto his officeand

readto her an Affidavit purportedly executed Def-endant by Cotewhich stated thatthe disk had beendestroyed. 179. In addition,he informedPlaintiffthat the computer pictures Plaintiff containing of

hadbeenturnedover to the IT department was being"wiped clean"and "recycled". and 180. Plaintiffrequested copy of this Affidavit and was informedthat Defendant a

Peterson would haveto get approval from Defendant Burnsto provideher with a copy. 181 . Plaintiffimmediately the offrceof Defendant left Peterson went to the office and

of Defbndant Burnsand inquiredwhethershecould havea copy of the Affidavit. 182. Defendant Burnswas and is awareof the eventsand circumstances this matter, of

andhe told Plaintiffat that time that he did not havea problemr,vith Plaintiffhavinga copyof theAffidavit. I 83. Defendant Peterson saidthat PlaintifT couldcomebackthe next day tbr a copy of

theAfhdavit. 184. ': Plaintiffreturned the ofllcethatday afterher shilt ended 5 PM and learned to at

thatDefbndant Pcterson lefi the offlceat 2 PM. had

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I 85.

PlaintiffcalledDet-endant Peterson his mobilephoneandhe told her thatshe on

couldpick up a copy of the Atlldavit next week,which was when shewas schedule to r,vork again. I 86. On February Plaintiff first regularly 7'l', s scheduled of work sinceFebruary day

I't, Plaintiffwent to Defendant Peterson's office to get a copy of the Affidavit. 187. At this time Defendant Peterson informedher that shewould not be receiving a

copy of theAffidavit at the recommendation the CountyAttorney's of Office. AS AND FOR A FIRST CAUSB OF ACTION DEFAMATION lB8. Plaintiffrealleges incorporates reference and by eachandeveryallegation

contained paragraphs - 187above. in 1 189. Plaintiffwasnot then,andis not now,nor hassheeverbeena promiscuous

person. 190. Defendant Cote'sstatements Plaintitfsboyfriend's to motherregarding Plaintiffs

virtueareblatantfalseand untrue. 191. party. 192. Def'endant Cotedefamed Plaintifl,because Plaintitfrefused cngage a sexual to in Def-endant intentionally Cote madethe statements regarding Plaintiffto a third

relationship with him. 193. Uponinfbrmation belief, and the.ICSD not fully andthoroughly did investigate

Plaintiff's complaint regarding defhrnatory the statements madeby Def'endant Cote.

2l

191.

Plaintiffdid not takeactionagainst Det-endant Cote for the defamatory statements,

because reliedon Defbndant she Peterson's representations the matterhad beenfully thal investigatec. 195. Plaintiffasserts this misrepresentation that regarding investigation material the is

to her decision not litigatethe matter. to and,as such,the statute limitationson her of pursuing claim against a Defendant Coteshouldbe tolled. 196. Defendant Cote's statements Plaintiffs motherwereinflammatoryin the to

extreme and caused serious injury to Plaintiffspersonal professional and reputation. AS AND FOR A SECOND CAUSE OF ACTION INTENTIONAL INFLTCTION OF EMOTIONAL DISTRESS 197 . Plaintiffrealleges incorporates reference and by eachand everyallegation

contained paragraphs - 196above. in I 198. As a resultof the incidents complained above,Plaintiffhassuft-ered of extreme

emotional distress. I99. Plaintiffhassuflbred extreme emotional distress, because Defendant Cotehas

sexually harassed PlaintifTand spread and rumorsaboutPlaintiff,and caused lies others to do the same, resulting serious in injury to Plaintiffs personal and professional reputation. 200. Furthermore, Defendant Cotehadandmay still havepossession sexual pictures of

of Plaintiff. 201. Plaintiffhasno ideahor.v manyauthorized persons viewedsexually alluring

photos her,dtteto the factthatthephotos of may havebcendownloaded onto Detbndant

22

Cote's work laptopcomputer, this cornputer accessible everyone the JCSO and was to in andthe .lef'ferson County [nforrnation Technology Department. 202. Plaintiffhasno ideahow manyunauthorized persons outside employof JCSO the

viewedsexuallyalluringphotosof her,dueto the fact that if the photosof Plaintiffwere on Defendant Cote'swork laptop,they may havebeenaccessible the Jefferson of County server. 203. Plaintiffagreed posefbr sexually to alluringphotosfor Detective Cote's online

investigation only 204. Plaintiffdid not agree havesuchphotoscopiedonto any otherdisk or to

computer, especially one that would be accessible Workcolleagues other to and employees Jefferson of County. 205. The photosof Plaintiffwereto be usedfbr Defendant Cote'sinvestigation only,

andwerenot for general viewing. 206. Plaintiffhadbeenassured Defbndants by Peterson Cote that no one would and

view the photoson that disk for any purpose that only Plaintiff and Defendant and Cote wouldhaveaccess the disk. to 207. By copyingPlaintiff's photos ontohis work laptop, computer a thatwasaccessible

to everyone the JCSO,Defendant in privatephotosof Plaintiffand Cotepublished violated right to privacy. her 208. : Copyingof Plaintiffsphotos ontoa work laptopis conduct that is morally

reprehensible is and rvouldbe highly offensive a reasonable and person. to

23

209,

Plaintifff-cels dirty, exposed extremely and embarrassed these by eventsand

incidents 210. Plaintiffwas distraught when shernade initial complaintagainst her Defendant

Cotein 2009,and whenher concerns weremet with indifference Defendant by Peterson, shefblt that Def-endant Peterson doing all he could to protectDefendant was Cote. 2ll. Plaintifffelt aloneand scared, felt that Defendant and Cote had takenthe pictures for personal gain,not any legitimate purpose, deparlmental otherwise, why was shenot beinggiventhe disk containing photos. the 212. Plaintiffbeganto feel paranoid that otherscould haveseenthe photosof her on

the disk, andthat therewas nothingshecould do to coritrolthe situation. 213. Furthermore, Plaintiffhasno intbrmation to how and by whom the photoswere as

transfbrred fiom the originalcamera onto the Disk. 214. Moreover, Plaintiffhasno information to how oftenthe photoswere accessed as

andby whom, because therewas no log kept regarding timesand datesof the viewingof the photos. 215. Evennow, Plaintiffbecomes physicallyill whenever thinks aboutthe fact that she

photos heron thatdisk couldbe in the possession almostanyone of of andshehasno recourse against unauthorized and viewing of her photos. use 216. This is not r,vhat Plaintiffagreed whensheagreed participated the to to in

investigation, believes wasexploited Defendant and she by Cote.

21

217.

Furthermore, Plaintiffis daily andcontinually subjected overtandcovertacts to

of hostilityby her coworkers, to her refusal abideDefe4dant due to Cote's behavior towardsher. 218. As a resultof the incidents complained above, of Plaintiffcannot rely on the

JCSD/JCSO administration investigate problems issues encounters work. to any or she at 219. Plaintiffis alr,vays watchingover her shoulder work, because cannottrust at she

her coworkers. that shedoesnot know who hasandr,villstartand/orperpetuate in false rumorsand lies abouther havingaffairsor illicit relationships. 220. This conductby Defendant Cotewasoutrageous, willful and/orreckless has and

caused Plaintiffextreme emotional distress, justify punitivedamages and against the Defendants that they will not engage suchconductagain. so in AS AND FOR A THIRD CAUSE OF ACTION BREACH OF DUTY UNDER RESPODEATSUPERIOR 221. Plaintiffrealleges incorporates reference and by eachand everyallegation

contained paragraphs - 220 above. in | 222. Det-endant Peterson comprised comprises "administration" JCSD/JCSO and the of

at all timesduringthe incidents alleged this Complaint. in 223. As an otlcer in the employof JCSD/JCSO, Defendants, supervisors, her oweda

duty of careto Plaintitfunderthe employer-employee relationship. 224. Specifically, Defbndants shouldhaveensured that Plaintiff would be protected

fiom malicious, willful and/orreckless against by thosein theiremployand/or acts her tunder theircontrol

25

225.

As a resultof the incidents cornplained above, of Plaintiffhassutlbred extreme

emotional distress. 226. Plaintifflearned afterthe lact that Defendant Cotehasa historyof sexually

harassing women. 227. This f-act was well known to the JCSD"administration" othersin the employ and

of JCSD. 228. Plaintiffwas shocked and sickened thatthe JCSD"administration" given had

Defbndant Cotepermission photograph body in variousstates undress. to her of 229. Plaintiffwas furthershocked and sickened thatthe JCSD "administration" had

allowedthis photosession occurwithoutthe presenoe anotherfemaleofficer. to of 230. In addition,Plaintiffwasevenmoreshocked that the JCSO"administration" had

allowedthe photosession occuroff siteat sucha secluded remotelocation. to and 231. By not informingPlaintiffthattopless photosof her shouldnot be takenby

Defbndant Cote,Defendants breached their duty of caretowardPlaintiff. 232. By not informingPlaintiffthat no photosof her shouldbe takenby Def'endant

Cotewithoutthe presence another of tbmaleofficer,Defendants breached their duty of caretowardsPlaintiff. 233. By allowing Defbndant Coteto drive Plaintiffaloneto a secluded spotto take

sexually alluringphotosof her,Def'endants breached their duty of careto Plaintiff. ': 234. By allowingDefendant Coteto takesexually alluringphotos Plaintiffoutside of the presence another of temaleofllcer,Def'endants breached their duty of careto Plaintiff'.

26

235.

By not rnonitoring Defbndant Cote's of the photosof Plaintiff,Def'endants use

breached their duty of careto Plaintift'. 236. By not beingableto produce Plaintiffa copy of the Contract the original for and

disk,Def-endants breached their duty of careto Plaintitf. 237. By not responding her requests production the Contract to fbr of and disk,

Def-endants breached their duty of careto Plaintiff. 238. By not investigation circumstances conditions the and underwhich the disk and

Contract havedisappeared, Defbndants breached their duty of careto Plaintiff. 239. By beingunableto providePlaintiffwith the disk containing photosof the

Plaintiff,Defbndant breached duty of careto the Plaintiff. his 240. Furthermore, Plaintiffis daily and continually subjected overtand covertacts to

of hostilityby her coworkers, to her refusalto abideDefendant due Cote'sbehavior towardsher. 241. As a resultof the incidents complained above, of Plaintiffcannot rely on the

JCSD/JCSO administration investigate problems issues encounters work. to any or she at 212. Plaintifl is alwayswatchingover her shoulder work, because cannottrust at she

her coworkers, that shedoesnot know who hasand will startand/orperpetuate in f-alse rumorsandliesabouther havingalfbirsor illicit relationships. 213. This conductby Def-endants JCSD/JCSO, Burnsand Peterson breached their duty

of careto Plaintitfancl wasoutrageous, willful and/or reckless hascaused and Plaintiff extreme emotional distress, justitiespunitive and damages against Def'endants that the so theyr.vill engage suchconduct not in again.

27

WFIEREFORE, Plaintilfpraysfbr judgrnent follows: as a. AgainstDefendants JCSO/JCSD, Burnsand Peterson underrespondeat superior

fbr breaching theirduty towards Plaintiff; b. AgainstDef'endant Cotefor detaming andintentionally inflictingemotional

distress uponPlaintiff; c. Compensatory damages f'avor Plaintiffin an amountthe court calculates proper in of as

andsufficient; d. Punitivedamages jointly and severally the amountof against Defbndants in

$s0.000.000.00. e. t. Court costsand attorney's feesfor the Plaintiff; and Any otherrelief the court deems properand appropriate. Respectfully submitted,

/.

CharuNarang,Esq. Attorneytbr Plaintiff 472 Brady Rd. Sackets Flarbor, NY 13685 Phone:646.234.9500

28

VERIFICATION I. KrystalG. Rice,beingduly sworn,do depose say: and I am the Plaintiffin the aboveentitledaction. I havereadthe foregoing Complaintand know the contents thereof-. The samearetrue to my knowledge, exceptas to thosematters stated upon information and belief,and as to thosematters. believethem to be true. I

KRYSTAL RICE G.
Swornto beforeme rhisllOtn*ae-y April- 2012. of
I i, I ('',.li')

Jalmc8. ThomPcon Publlc'Stataol NswYotl NotarY No' MTH8215247 CoqV : In Orralil'toclJolforaon Erplrer l'zllbl -i-L' Cornnrluokm

29

EXHIBIT 1

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COUNTY OF JEFFERSON

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DEPARTMENT HUMANRESOURCES OF
S I E P H E NR , M I L L E R Directorof H u m a nR e s o u r c e s Civil Service L a b o rR e l a t i o n s

COUNTOFFICE UILDING Y B 175ARSENAL STREET WATERTOWN. YORK NEW 13601-2568 ( 3 1 57 8 5 - 3 1 4 7 ) (315) FAX: /8$5052

V A L E R I EM . B O R L A N D Human ResourcesAssociate

D e c e m b e2 , 2 0 0 5 r Krystal Rice 221 N. Orchard St. Watertown, 13601 NY

DearMs. Rice: In order to be further considercd pennanent for appointmentas Deputy Sheriff, you must now complete physical a exantination. You areherebydirected contact to Occupational Medicine Associates,200 Mullin Street, Watertown, NY at 782-9125.An appointment shouldbe madeprior to December 2005. 9, Additionally,I havecnclosed physicians a release form which you rvill leecl to havecompletecl for the next stepin the screening process. Please contactthis otlice shouldyou haveany questions.

Verytruly yours,

{^tAV on/^__ValerieM. I]orland Ijuman Resoruces Associate

Hnc . cc: I)u\L'al,nelirancis,Occupatiorraliv{cdicine S hc r i ff Bu ms

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EXHIBIT 2

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ond s'er&e

Sheriff JffusonCaunry of
JOHN P. BTJR.NS SIIERIFIT A r e aC o d e( 3 1 5 ) F.rrrergencyI 9l 86-2660 Adm istration'l in l-awEnforcement'7 | 86-267 Corrections 786-2688

753 WatermanDrive Watertown. New York 13601

t,ARRYM. JOBSON TINDERS}{ERIFF

tlivilOfllce 786-2714 I(ccords OtIicc 786-270 I PistolPermiLs 86-27 | 7 | CourtSecurily 786-7408

January 6,2006

Krystal G. Rice 221 North OrchardStreet Watertolvn, NY 13601 Dear lv{s.Rice I am pleased arlviseyou that you havebeenchosenlrom amongthe list of cligible to candidates appointmcntas Deputy Sheriffwith the Jefferson for County Sheriffs Office. Your appointmentwill be eflbctiveTuesday, January10, 2006. This appointment will be probationaryfor one year. Please report to the Oflice of the SheriIIon Tuesday,January10, 2006, at 9:00 a.m. for . orientation.

JPB:smb cf: J.C. Dept. of t{rimanResources

i lcart of the Thousrnd lshnds

Addres.sall cornnrunicationsto the Sheriff of .Jefferson County payable to the Sherlff of Jefferson County l{ake ail checi<s

EXHIBIT 3

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ACADEMY

GRADUATE

Mny I9, 2006

JEFFERSoN CoUNTY DEPUTY SHERIFF's AssocIATIoN WnrERTowN, NEw YoRK

LET IT BE RECOGNIZED AND APPREcIATED THAT DepUTY

SgeRIFF

KnysTAL

G. RTcE

UPON YOUR COMPLETION OF BASIC TRAINING IN AN EXEMPLARY FASHION AND qUALIFYING AS A POLICE OFFICER UNDER THE RIGID TECHNICAL REQUIREMEHTS E5TABLISHED BY THE BUREAU OF MUNICIPAL POLICE gTANDARDS AND THE DIVISION OF CRIMINAL JUSTICE SERVICES OF THE STATE OF NEvy YORK

PRESIDENT

JEFFERSoN

CoUNTY

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President Sindy,4friat Vice President Zachery Smacher Secretury Hcother Binmonte Treusurer Duslin De[eel Senutor Cultlyn IIill .ltlvisor Dn Slevcn Gilbert

Omego Upsifon
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November2L,2008 Dear Depulv Rice: On behalfof the members the OmegaUpsilonchapter the Alpha Phi Signra of of NationalCriminal JusticeHonor Sociery, rvantto thankyou onoeagainfor your I participationat our annual induction ceremony.We appreciate your willingnessto share your insightregarding universify'scriminal investigations the degreeaswell as career development. Having a criminal investigationsgraduate keynotespeakerwas a meaningful as cxperience our mernbers for which will no doubtprovideencouragement towardsseeking success their endeavors. in Sinccrely,

C,b{^^t A-"a-i
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SUPRENIE couRT oF TFIE sTr{rEoF NEw yoRK

COTJNTY F JEFFERSOI\ O KRYSTT\LG RICE. Plaintiff, -againstJ E F F E R S O N O U N T YS H E R I F F ' S F F I C E , C O a lnunicipalentity, JOHN P. BuRNS,indivirlually' a n d i n h i sc a p a c i t y sS h e r i t f a of the Jel'ferson Countl' Sheritf s Olllce, NIICHAEL PETERSON,indivicluaily ancl in his capacityas Lieutenantof the Jell'erson County Sherifi's Oflice, STEVEN COTE, individuallyand in his capacityas Detective the Jetferson of Countv Sherill's Oltice,jointly and severally, Defendants. I n d e xN o . :

PART I30 CERTIFICATION

I lrereby cerlifypursuant 22 NyCRR $ 130- l-a that,to the bestof nry knowledge, to l. infbrmation and belief,fbrmedafteran irrquiry reasonable underthe circumstarlces, presentation the paper.s tlre of listecl belor,v the contentions or therein not fiivolousas clef are rnedin 22 NYCRR $ t 30-I . t (c):
)'' 't ( / (r'

Datcd: February 2012 14 Sackets Harbor, NY

CharuNarang, Esq. 412 Brady Rd. Sackets Harbor, Ny 13685 Phone:646.23L9500

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