AFFIDAVIT OF ILLEGAL DISCRIMINATORY ffiffiilffi

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CHRONO. /oZalcl7 EEOC NO. 'i$gb'+ ['gs,. ff h'ffi f$,f;i-

L My name is Mastda Salohuddin and I reside at 5 *ilInIH

Connecticut.

2. My mailing address is the same.

3. The Respondent is the City af Ansonio, the Ansonia Police Department and
-
Chief of Police Kevin Hale located at 253 Main Street Ansonia CT, and 2 Elm Street

Ansonia CT.

4. I have been constantly retaliated against since I began my empioyment with the

latest instance occurring on or about October 9,2009. This retaliation consisted of my

employer, the City of Ansonia's Police Department, by and through the decisions and

actions of its Chief of Police, Kevin Hale, instituting a baseless, and conveniently timed,

internal affairs investigation against me regarding prior conduct on the part of the

Ansonia Police Department and Chief Kevin Hale referenced below. Chief Hale

ordered that I participate and provide an interview regarding alleged conduct that resulted

in my arrest and placement on administrative leave as a way to retaliate against me for

filing a prior CHRO complaint that related specifically to actions he has taken while in

office. In addition, Chief Hale took such action as retaliation for my decision to fight the

false criminal allegations he personally requested be brought against me. In addition,

Defendant Hale treated me differently from all other members of the department as he

included allegations in this investigation relating to conduct that was a cofilmon practice
of the department and its employees, conduct which supervisors had approved and

conduct for which no other officer had ever been made the subject of an internal

investigation.

5. This all stems from my July 15, 2009 arrest and placement on administrative

leave.

6. I believe that my race (African-American), my color (black), my religion (Islam)

ond my previously having oppased discriminatory conduct (ogainst both myself and

others), and my asserting my First Amendment Rights infiling a prior complaint with
the CHRO and speoking out agoinst hk actions relating to me, were in part lactors in

this action. I believe that the respondent violated the following Connecticut General

Statutes and Acts listed below.

46a-58(a) a6a-60(a)(1 ) 46 a-60(a)g) a6 a-60(aX7)

46-64a 46a-81 46a-80 a6a-60(a)(S)

Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e and the

Civil Rights Act of 1991 (15 or more employees)

2
 COMPLAINT
l) The parliculars of my complaint are as follows:

2) My name is Mustafa Satuhuddin and I reside atllGnttF

Connecticut.

3) My mailing address is the same.

4) The Respondent isthe City of Ansonia, the Ansonia Police Departrnent and

Chief of Police Kevin Hale withbusiness addresses of 253 Main Street Ansonia CT, and

2Elm Street Ansonia CT.

5) I have been constantly retaliated against since I began my employment with the

aforementioned parties with the latest instance occurring on or about October 9,2009.

This retaliation consisted of my employer, the Ansonia police Department, by and

through, its Chief of Police Kevin Hale, instituting an internal affairs investigation

against me regarding prior conduct on the pa* of the,4 nsonia Police Department and

Kevin Hale referenced below. Chief Kevin Hale ordered that I participate and provide

an interview regarding alleged conduct that resulted in my arrest and placement on

administrative leave as a way to retaliate against me for filing a prior CHRO complaint.

In addition, Chief Hale took such action as retaliation for my decision to fight the false

criminal allegations he personally requested be brought against me. In addition

Defendant Hale treated me differently from all other members of the department as he

included allegations in this investigation relating to conduct that was a common practice

of the department and its employees, conduct which supervisors had approved and

conduct for which no other officer had ever been made the subject of an internal

investigation.
 6) I believe that my roce (African-American), my color (black), my religion (Islom)

and my prevtoasly hoving opposed discriminutory conduct (ogainst both myself ond

others) were in parl factors in this action. I believe that the respondent violated the

proceeding Connecticut General Statutes and Acts listed on the proceeding page.

7) The respondent employs more than l5 persons.

8) I began working for the respondent in 1993 in the capacity of a police officer.

g) All of my performance ratings up to and including the most recent rated me

satisfactory or better and I have received numerous departmental service awards.

10) I began part-time employment with the respondent in 1993.

I 1) I repeatedly made attempts to obtain a full time position and was denied such a

position for years.

12) Eventually I made a complaint in regard to the City of Ansonia's failure to hire

me for a full time position with the NAACP. After making my complaint I was

interviewed and offered a full time position.

13) After obtaining this position I was subjected to constant harassment at the hands

of my superiors. This harassment included racial slurs and derogatory comments.

14) In 1998 I filed a complaint with the commission on Human Rights and

Opportunities due to the fact the Ansania Police Departmenl denied me the right to wear

a beard- A practice that is extremely important to the practice of my religion. I prevailed

in this complaint and as a result gained the right to wear my beard.

15) In addition to wearing a beard I also was allowed to openly practice my religion

in the form of being allowed to pray at certain times during the day.
 I6) These developments angered my superiors and they took every opportunity to

retaliate against me as a result.

17) Eventually I decided to exercise my right to engage in union activities and

decided to run for the position of union president.

18) My decision outraged my supervisors and as a result they continued to retaliate

against me.

19) This retaliation included failing to take action against other employees who were

openly hostile towards me because of my race and initiating and subjecting me to

frivolous intemal affairs investigations, after which I was not only cleared of any wrong

doing but issued an award for the manner in which I conducted myself.

20) In July of 2007 a questioruraire was circulated in regard to the Department's

Harassment and Discrimination Policy. This questiomaire asked if I was aware if any

employee had been subjected to harassment. I answered yes to this question.

21) I was then questioned about my answer by Lt. Cota, an officer in a supervisory

capacity and declined to discuss the matter with him but instead asked who other than

him I could speak rvith.

22) A female officer had been the victim of sexual harassment at the hands of a

superior officer and I was a witness to this. I counseled this officer and offered help in

any way that I could, againangering my superiors.

23) I also spoke out against and supported others individuals in the City of Ansonia

who had their rights been violatedby Ansonia Chief of Police Kevin Hale.

24) These actions again angered my superiors, most specifically Ansonia Chief of
Police Kevin Hale.
" 25) This summer I was accused of stealing a garden hose from the Ansonia Police

department.

26) This hose was found within the department three days after it was reported

missing by the same individual who had initially reported it missing.

27) Despite the fact this hose was found inside the departm ent, Chief of Police Kevin

Hole requested the Connecticut State Police conduct an investigation and that I be

arrested.

28) I was arrested and placed on administrative leave which continues as of the date

of this complaint.

29) I never stole this garden hose as it never left department property.

30) In the past town employees have been accused of and admitted to engaging in

thefts and these employees were not arrested.

31) With the aforementioned false arrest as a basis, Chief Kevin Hale used his

position as Chief. and the authority vested in that position, to order, that I, pursuant to

contract, actively participate and provide an interview regarding alleged conduct that

resulted in my arrest and placement on administrative leave as a way to retaliate against

me for:

A) Filing a prior CHRO complaint.

B) My decision to fight the false criminal allegations he

personally requested be brought against me.

32) Defendant Hale treated me differently from all other members of the Departrnent

as he included allegations of misconduct:

 OATH
I request the Connecticut Commission on Human fughts and Opportunities to investigate

my complaint- secure for me my rights as guaranteed to me under the above cited laws

and secure for me any remedy to which I may be entitled.

Mustafu Salohuddin being duly sworn, on oath, states that he is the Complainant herein,

that he has read the foregoing complaint and knows the content thereof, that the same is

true of his own klowledge, except as to the matter herein stated on information and belief

and that as to these matters he believes the same to be true.

Dated at vl/aterbury, connecticut this 2nd day of N}WMBER 2009.

Subscribed and sworn 2nd day of I\

Rob Serafinowicz

Commissioner of the Supertor Court (#423695)