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Berg Lawsuit

Berg Lawsuit

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Published by mbrackenbury

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Published by: mbrackenbury on Feb 17, 2012
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02/17/2012

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UNITED
STATES
DISTRICTCOURTDISTRICT
OF
CONNECTICUT
ERICA BERG
Plaintiff,
cy
vs.
LEONARD GALLO :
Defendant, :
MICHAEL SORBO
Defendant, :
OFFICER EMERMAN
Defendant, :
OFFICER FINOIA
Defendant, :
OFFICER JOHN MILLER :
Defendant, :
SERGEANT KATTIS
Defendant,:
MAYOR JOSEPH MATURO
Defendant, :
SGT. FRANK MONTAGNA
Defendant, :
UNKNOWN JOHN DOE OFFICERS
Defendants.
TOWN OF EAST HAVEN, CT
Defendant.
COMPLAINT
1.
This is an action to redress a conspiracy by the defendants the object of which was to
 
utterly deprive the plaintiff of civil rights secured to her by the Constitution and laws of theUnited States, as well as those of the State of Connecticut, and by any notion of commonhuman decency. This conspiracy was so low, and so shadowy, and motivated by suchpetty ambitions as to resemble nothing so much as a sad, cruel parody of an organizedcrime family. In this case, armed with badges and authority, the conspirators took aim atthe plaintiff with the intent to punish her for her political affiliations and beliefs, and at thesame time to further their own political aspirations and designs on town control. Whentheir cancerous conspiracy came to light, they offered "protection" and favors. Theplaintiff, undeterred, would not be so deprived of her rights and she brings this actionseeking justice.
2.
By way of the acts and omissions, policies and practices more fully described below,the defendants caused the False Arrest and Malicious Prosecution of the Plaintiff Erica
Berg,
and said claims arise under the Fourth Amendment to the United StatesConstitution. The defendants also engaged in conduct that denied the plaintiff equalprotection of the laws as guaranteed by the Fourteenth Amendment, and retaliatedagainst the plaintiff for having exercised rights guaranteed to her under the FirstAmendment. In the manner described herein, the defendants deprived the plaintiff of herright to be free from false imprisonment, false arrest, malicious prosecution, defamationand intentional infliction of emotional distress under the laws of the State of Connecticutwhich is invoked under the supplementary jurisdiction of this court.3. Jurisdiction of this Court is invoked under the provisions of
§§1331,
1343(3) and1367(a) of Title 28 and §§1983 and 1988 of Title 42 of the United States Code.
2
 
4.
During all times mentioned in this Complaint, the plaintiff Erica Berg was, and still is, anadult resident of the State of Connecticut, residing in Branford, Connecticut.5. During all times mentioned in this Complaint, the defendant LEONARD GALLO was,and still is, an adult resident of the State of Connecticut, employed as a law enforcementofficer by the Town of East Haven, acting under color of law. His business address is EastHaven Police Department, 471 North High Street, East Haven, CT. He is sued in hisindividual capacity.6. During all times mentioned in this Complaint, defendant MICHAEL SORBO was a lawenforcement officer, and former Republican candidate for Town Council, employed by theTown of East Haven acting under color of law. He is sued in his individual capacity only.7. During all times mentioned in this Complaint, defendant Officer EMERMAN was a lawenforcement officer employed by the Town of East Haven acting under color of law. He issued in his individual capacity only.8. During all times mentioned in this Complaint, defendant Officer FINOIA was a lawenforcement officer employed by the Town of East Haven acting under color of law. He issued in his individual capacity only.9. During all times mentioned in this Complaint, defendant Sergeant KATTIS was a lawenforcement officer employed by the Town of East Haven acting under color of law. He issued in his individual capacity only.
10.
During all times mentioned in this Complaint, defendant JOSEPH MATURO waseither a high ranking member of the Republican Party of East Haven or mayor of East3

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