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Susane O. Grasso v. Connecticut Hospice

Susane O. Grasso v. Connecticut Hospice

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Published by estannard
Susane Grasso sued Connecticut Hospice of Branford, claiming she was harassed into leaving her job after reporting a defective chair to OSHA.
Susane Grasso sued Connecticut Hospice of Branford, claiming she was harassed into leaving her job after reporting a defective chair to OSHA.

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Published by: estannard on Jul 16, 2010
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07/18/2010

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'SUMMONS - CIVIL
JD-CV-1Rev. 10-09
C.G.S.§§ 51-346, 51-347,51-349,51-350,
52-45a,
52-48,52-259,
P.B.Sees. 3-1through 3-21, 8-1
STATE OF CONNECTICUT
SUPERIOR COURT
www.jud.ct.gov
See page 2 for instructions
o~IXIIifamount) legai interestOi property in demand, not including interest and
costs is less than$2,500.
"X"if amount, legal interest or property in demand. not induding interest and
costsis$2,500 or more.
"X "if claiming other relief in additionto Dr in lieu of money or damages.
TO: Anyproper officer; BYAUTHORITY OFTHE
STATE OF CO~JNECTICUT1you are hereby
commanded to make due and legal serviceof
this Summons and attached Complaint.
Address of court clerk where writand other papers shall be filed(Number, street, town and zip code)
(GG.S.§§51-346, 51-350)
235Church Street, New Haven 06510
Telephonenu rnber of clerk
(with area code)
( 203 ) 503-6800
Return Date(Must bea Tuesday)
August
3.2010
Day
--v e ar -
Month
'X lJudicial District
jAt(Townin '('hich writ is returnable)(C.G.S.§§51-346, 51.349)
~
G.A.
DHousing Session
0Number:
New Haven
For the Plaintiff(s) please enter the appearanceof:
Casetype code(See list on page 2)
Major: C
Minor:90
Name and address of attorney, lawfirm or plaintiffif self-represented(Number, street, town and zip coda)
IJuris number(tp be enteredby attorney only)
Perelmutter,
Potash& Ginzberg,
P.C.
046117
Telephone number(witharea code)
ISignatureof Plaintiff(Ifself-represented)
(203 )888-2501
Number of Plaintiffs:
1
rNumber of Defendants:
8
lIZ !FormJD-CV-2 attachedfor additional parties
Parties
Name(Last, First, Middle Initial) and Addressof Eachparty(Number; Street;P,O, Box; Town; State; Zip; Country,if not USA)
First
Name:
~rasso.
SusaneO.
P-01
Plaintiff
Address:
Additional
Name:
P-02
Plaintiff
Address:
First
Name:
Connecticut
Hospice, Inc.
D-50
Defendant
Address:100Double Beach Road, Branford,
CT06405
Additional
Name:
Hurzeler,
Rosemary
J.
D· 51
Defendant
Address:11 Double Beach Road, Branford,
CT06405
Additional
Name:
Knight,
Ronny J.
0· 52
Defendant
Address:100Double Beach Road, Branford,
CT06405
Additional
Name:
Goldfarb,
DavidR.
0-53
Defendant
Address:100Double Beach Road, Branford,
CT06405
Notice to Each Defendant
1. YOUARE BEINGSUED. This paper isa Summons in a lawsuit. The complaint attached to these papers states the claims that each plaintiff is making
against YDUin this lawsuit.
2.To be notified of further proceedings, you or your attorney must file a form called an "Appearance" with the clerk of the above-named Court at the above
Court address on or before the second day after the above Return Date. The Return Date is not a hearing date. You do not have to come to court on the
Return Date unless you receive a separate notice telling you to come to court.
3.If you or your attorney do not file a written "Appearance" form on time, a judgment may be entered against you by default. The "Appearance" form may be
obtained at the Court address above or atwww.jud.ct.govunder"Court
Forms."
4. Ifyou believe that you have insurance that may cover the claim that is being made against you in this lawsuit. you should immediately contact your
insurance representative. Other action you may have to take is described in the Connecticut Practice Book which may be found in a superior court law
library or on-line atwww:lud.ct.gov under "Court Rules."
, If you have questions a 'ut the Summons and Complaint, you should tal k to an attorney quickly.The Clerk ofCourt is not allowed to give advice on
legal questions.
'
Nameof Person Signing at Left
Jeffrey
D. Ginzberg, Esquire
Date signed
7/6/2010
Commissioner of the
Superior Court
Assistant Clerk
.
,
..
IS SumrponsIS SIgned
he sig -ng has been done so that the Plaintiff(s) will not be denied access to the courts.
is t
responsibility of the Plaintiff(s) to see that service is made in the manner provided by law.
c. The Clerk is not permitted to give any legal advice in connection with any lawsuit.
d. The Clerk signing this Summonsat the request of the Plaintiff(s} is not responsible in any way for any errors or
omissions in the Summons, any allegations contained in the Complaint, or the service of the Summons or Complaint.
Icertify Ihave read and
Signed(Self-Represented Plaintiff)
understand the above:
Date
ForCourtUSe Only.
File Date
IV!Commissionerof the
~
SuperiorCourt
Assistant Clerk
Date
716/2010
,~ 'X "proper box)
(Page 1 of 2)
Docket Number
CIVIL SUMMONS
CONTINUATION OF PARTIES
STATE OF CONNECTICUT
SUPERIOR COURT
JD-CV-2 Rev.4-97
FIRST NAMED PLAINTIFF(Last, First, Middle Initial)
Grasso, Susane O.
FIRST NAMED DEFENDANT(Last, First, Middle Initial)
Connecticut Hospice, Inc.
~,,:f,iE<'i"~<;;';·<\':"
,../;.', ..·..f, ...•
',"
.'
...• "
:AIlOITIONA1:J:iI?LAINllfFS',,'
"iF,
•.• '•.•.• '
.•..•
\ .•.•. ':,;.;'
'/
ii.,i,;(;!',.~,,".~tt,
NAME(Last, First, Middle Initial, ifindividual)
ADDRESS(No., Street, Town and ZIP Gode)
CODE
NAME(Last, First, Middle Initial,if individual)
ADDRESS(No., Street, Town and ZIP Gode)
Kilmas, Sandra,J. 100 Double Beach Road, Branford, CT 06405
Flannigan, Susan, 100 Double Beach Road, Branford, CT 06405
Baranowski, Nancy, 100 Double Beach Road, Branford, CT 06405
Sweeney, Michael, 100 Double Beach Road, Branford, CT 06405
62
FOR COURT USE ONLY - FILE DATE
63DOCKET NO.
CIVIL SUMMONS-Continuation
03
04
05
06
07
08
09
10
11
12
13
CODE
54
55
56
57
58
59
60
'ERELMUTTE;R, POTASH
&GINZ BERG, P.C.
ATTORNEYS&
:OUNSELLORS AT LAW
11 BANK STREET
P.O.BOX 1
EYMOUR. CONNECTICUT
064B3-0001
TEL (203) 888-2501
FAX (203) 888-7928
JURIS NUMBER
46117
II
RN DT:
AUGUST 3, 2010
SUPERIOR COURT
SUSANE O. GRASSO
··
J.D. OF NEWHAVEN
VS.
AT NEWHAVEN
CONNECTICUT HOSPICE, INC.,
RosemaryJ. Hurzeler,
RonnyJ. Knight
David R. Goldfarb
SandraJ. Klimas
Susan Flannigan
Nancy Baranowski
Michael Sweeney
··
July 6,2010
COMPLAINT
I. PARTIES:

1. Connecticut Hospice, Inc, (hereinafter referred to as "CTHI") is a corporation organized existing under the laws of the State of Connecticut as a non- profit corporation the operation of which is governed by a board of directors. The individual defendants are RosemaryJ. Hurzeler, President and CEO, Ronny J. Knight, Sr VP,David R. Goldfarb, Sr VP and CFO, SandraJ. Klimas, VP of Clinical Services, Susan Flannigan, Assistant Dir of Home Care, Nancy Baranowski, Supervisor of Residential Programs, and Michael Sweeney, RN. The individual defendants are being sued in their individual capacity for actions taken under color of authority granted by CTHI, but in excess of or in violation of such authority for purposes of personaladvantage within the "chain of command" of CTHI.

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