TOWN OF SMITHTOWN COUNTY OF SUFFOLK AIMEE LYNN SMITH (SSN: XXX-xXx ~ against - NOTICE OF CLAINE. & 5 ‘TOWN OF SMITHTOWN; GLENN JORGENSEN, 3B a ‘TOWN OF SMITHTOWN SUPERINTENDENT 2 im OF HIGHWAYS zon iss 20 To: Town of Smithtown Bown 99 W. Main St. cc P.O. Box 646 ‘Smithtown, NY 11787-0646 I, Name and address of the claimant Aimee ~ Smith U1, Describe the nature of the claim, naming the claimant and the defendant and b escribing what ed. 1, Aimee Lynn Smith, have been systematically subjected to an ongoing pattern and practice of: discrimination based on gender, and subjected to a hostile work environment, sexual harassment, and an unlawful termination. Said actions, as more fully set forth below were done by the above named Town of Smithtown; Glenn Jorgensen, Town of Smithtown Superintendent of Highways. If. Date, Time and place of the incident. ‘The following is the treatment I have been subjected to, which encompasses the behavior of the aforementioned individuals, the main site of the occurrences were at the following address: 758 ‘Smithtown Bypass, Smithtown, NY 11787, and all are stated upon information and belief: 1, I was hired by the Town of Smithtown Department of Highways on November 25, 2013 as a secretary to the Superintendent of the Town of Smithtown Department of Highways. Upon beginning my employment I was advised I also had to fill-in as a general Secretary while another secretary, Brynne Blohm was on leave. Page 1 of 162. Upon the other secretary returning on or about January 2014, I was made the secretary to Glenn Jorgensen. 3. At no point was I provided with orientation, as other employees had been given. On or about November 25, 2013, I was given a debriefing with Meg Marigliano, who works in the Personnel Department to sign benefits forms. 4, In or about Spring 2014, Mr. Jorgensen and I were behind the main office located at 758 Smithtown Bypass, Smithtown, NY 11787, by the parking lot watching the tower being serviced or repaired. A person from Public Safety, whose name was, upon information and belief, Andy Brofman, was present. When Brofiman stepped away for 2 moment, Mr. Jorgensen unclasped his hands from bebind his back to lift them up and point at something with the tower, hitting my rear. Mr. Jorgensen immediately apologized and claimed he didn’t mean to touch me. However, based on subsequent events and his relative close proximity to me I do not believe it was an accident. 5. Onor about December 31, 2013, Mr. Jorgensen commented about the lunch I had for my birthday with a man I had been dating. Mr. Jorgensen commented that the man opened the car door for me to get in which made me uncomfortable because I felt like Mr. Jorgensen was spying on me. In order to see me get into the car, Mr. Jorgensen would have been watching out one of the windows from his office to sce the parking lot. However, when I left for the lunch Mr. Jorgensen was sitting in the main office. 6. In or about January 2014 Brynne Blohm, retumed to work. However, a couple of weeks before she returned Mr. Jorgensen personally took me to Staples to look for a desk and chair, knowing Blohm was returning to work soon. Upon information and belief, Mr. Jorgensen did the same with another secretary, Joanne Dellasperanza. a. After looking for a desk and chair, Mr. Jorgensen took me out to brunch at the Lake Grove Diner, located at 2211 Nesconset Highway, Lake Grove, New ‘York. He explained that he meets with Bill Majuk, his campaign manager, at this diner often. b. During the breakfast Mr. Jorgensen asked me personal questions and about the guy I was seeing: What he did for a living; How much money he made; If he treated me nicely; How long had we been seeing each other. c. Mr, Jorgensen did comment that my at the time boyfriend was “a lucky guy.” d. As we left the diner, Mr. Jorgensen asked, “Want me to get [car] the door for you (like your date (did))?” Mr. Jorgensen made this type of comment frequently any time we were out alone. Another frequent joke Mr. Jorgensen started was calling me a “cheap date’ since I never ordered much to eat when he took me out. Page 2 of 167. On or about January 3, 2014, I was alone with Mr. Jorgensen to visita site. During the car ride I was texting my grandfather to wish him a happy birthday. Mr. Jorgensen asked who I was texting, and always seemed to ask whom I was texting whenever I was on my phone, even if I was not texting anyone. 8. In the time following the aforementioned breakfast Mr. Jorgensen, would continue to ask me personal questions. These questions would be asked of me anytime I was alone with Mr. Jorgensen, whether in the office or out on the road. The questions varied from: How many kids I had, their ages and names, how active my ex-spouse was with them, the status of me and my ex-spouse, How my children were adjusting to daycare, about my previous job, if I had any siblings and about them, about my parents and my grandfather, and how I was liking the new job. @. Mr. Jorgensen would also ask frequent questions like: “Do you have kids tonight or does your ex? Do you have any dates planned?” If I did, the following day I would be peppered with questions about the date: Where did ‘we go to eat, who drove, did he pay, and what time did I get home from the date. b. I did not feel comfortable answering, Mr. Jorgensen immediately laughed it off and said I did not have to answer. “Be home by midnight” became a constant remark if Mr. Jorgensen if he knew J had a date planned. 9. Throughout the course of my employment Mr. Jorgensen would take me to places where the Town had no known business. For example: a. Early in my employment Mr. Jorgensen and I drove through the Kings Park Psychiatric Hospital. Mr. Jorgensen told me about the history of the Hospital. ‘He then drove off the main road and down a dirt path to get a better look at one of the buildings, but an official quickly arrived to investigate what we were doing. Mr. Jorgensen told the official we were just looking and meant no harm and we left. b. Mr. Jorgensen had, on at least one occasion, brought me to his home under the pretense that he needed to pick up a blank check from his wife. I remained in the car, while Mr. Jorgensen went inside. Mr. Jorgensen would make a point of telling me that he talked to his wife 2 lot about me and about my children. ‘There were other times that, when we were driving to sites, that Mr. Jorgensen would pass-by his house, with no expressed reason as to why. 10. Mr. Jorgensen would often take me to complaint sites. a. In early spring 2014, Mr. Jorgensen took me to the Hauppauge Diner, located at 525 Smithtown Bypass, Hauppauge, New York 11788. Mr. Jorgensen complained he wasn’t feeling good and explained that he had not eaten. Mr, Jorgensen had previously made me aware that he was a diabetic, so I did not Page 3 of 16want to stop him. The meal felt awkward and most of the time Mr. Jorgensen spent reading the newspaper. I feel like his health became an easy transition for Mr. Jorgensen to quickly stop somewhere to eat with me. b. In mid-Spring 2014, Mr. Jorgensen took me to a site followed by lunch at a American Roadside/American Burger Company restaurant in Smithtown right on Main Street. He made a comment that the employees at the restaurant “probably thought he was my dad.” I did not understand where the comment arose from and began to wonder what he was thinking about me. The whole meal he seemed uncomfortable and even asked me how I would feel if someone from the Highway Department saw us eating lunch together. 11. Mr. Jorgensen was the Secretary for the Suffolk County Highway Superintendents ‘Association (SCHSA), so as his secretary, I handled the mailings and address book for the organization. In or about March 2014, Mr. Jorgensen asked me to go with him toa meeting for SCHSA so I could meet some of the other members of SCHSA. We went to Lily Flannigan’s in Babylon. The event was hosted by Tom Stay, the DPW Commissioner of Babylon. 1 was introduced to many vendors and felt flaunted and “shown off” as many of the men made comments and remarks to Mr. Jorgensen about how “lucky” he was to have me as his personal secretary. I always took it as a compliment yet attack towards my appearance and youth. At firs, it was flattering, but it quickly became annoying and uncomfortable, especially when several men began hitting on me. 12. At the next SCHSA meeting in April, Mr. Jorgensen and 1 went to Lombardi’s on the Sound in Port Jefferson, hosted by Daniel Losquadro, the Highway Superintendent of Brookhaven. I was made to believe that I was needed for this meeting because there was an executive meeting that took place beforehand and I needed to take notes for Mr. Jorgensen. During the main event when the rest of the vendors arrived, my introduction slightly changed as I was now presented as Mr. Jorgensen’s “new, personal, private secretary.” He would then tum to me and say, “Now don’t get mad at me,” then tum back to whoever I was being introduced to and he would say, “And the best part is I can fire her whenever I want.” He would then explain my exempt status, though it began to come across more like he owned me, not the position. When T tried to explain my dislike to him, in that he was sharing that he held my job over my head. Mr. Jorgensen insincerely apologized and defended himself by saying that it ‘was true, that he could fire me at any time, Anywhere we went, whether the SCHSA. or speaking with residents, I felt shown off, but it became quite uncomfortable as it seemed Mr, Jorgensen was recognizing the attention he got (because of the attention I brought) for having me with him. I did not like feeling flaunted or owned. 13. The same introduction at the SCHSA meetings of being Mr. Jorgensen’s “personal, private secretary” was also used whenever someone visited the Highway Department office. Mr, Jorgensen would say, “I have to show you off because I show all my girls off.” I refused to go to the May SCHSA function in Riverhead because I did not feel like I needed to be in attendance since there was no executive meeting, and felt he Page 4 of 16was only inviting me for the attention. He even joked at one point saying if I wore a skirt, I could probably meet a nice rich man at one of the functions since 1 had recently become single. Mr. Jorgensen made me feel guilty for not wanting to go with him by saying I was “blowing him off”. This same line was used when I began declining his invitations to go with him to breakfasts and lunches. I began making up excuses of things I had to do on my lunch break so Mr. Jorgensen could not make me feel guilty for not going anywhere with him, 14. Mr. Jorgensen did acknowledge his awareness of the attention I received by telling me how I was the best looking girl at the SCHSA functions, to which I quickly retorted there were only two other women present out of about 70 guests, and I was half their age. He argued that I really was a beautiful girl and was in great shape, especially for a mother of two kids. He said he wasn’t trying to be inappropriate, just stating the obvious and I should already be aware of my looks. 15. When Mr. Jorgensen asked me to the July 2014 SCHA event, hosted by Alex Gregor, the Highway Superintendent of Southampton, I insisted the other secretary Brynne Blohm come with us because she was a great co-worker and deserved to be taken out of the office once in a while too. The three of us went to Oakland’s in Hampton Bays. I was very glad to have Brynne Blohm's company. I also insisted Mr. Jorgensen start taking Brynne Blohm out to breakfasts because it had become obvious he was only taking me out and I warned him how uncomfortable it was making me feel. I then refused attending the next two SCHSA meetings, as by this point in my employment, I was feeling very uncomfortable being alone in the car with Mr. Jorgensen and wanted to minimize the opportunities for Mr. Jorgensen and I to talk personally, 16. Mr. Jorgensen gave me further attention which made me feel like I was his property. For example: a. He bought me business cards, while upon information and belief, none of his previous secretaries had business cards, nor did any of the other secretaries. b. In or about September 2014, Mr. Jorgensen also wanted me to order a jacket and kept focusing on making sure I had it labeled as his secretary. When speaking to Joe Cannone and Steve Cameron, the gentlemen who order the clothing for the Highway Department, they stated that it was odd Mr. Jorgensen wanted me to order a jacket since none of the other office girls had ever received one, nor did Mr. Jorgensen make this a new policy and instruct the other girls to order one as he was telling me. 17. Mr. Jorgensen told me he only knew a few words in sign language; and the signage for ‘beautiful’ was one he knew and showed me. He then began signing this to me around the office. Seldom at first, but towards the summer of 2014 it was a few times a week. It was also becoming quite common for Mr. Jorgensen to tell me how nice I looked at the office, and verbally stated numerous times that I was “frickin’ gorgeous.” For his campaign fundraiser, which I believe took place at some time in Page 5 of 16early May, Mr. Jorgensen asked me to be at the front door to greet guests as they arrived so they had something nice to look at when they first entered Espana, the restaurant in St, James where the event was held. At some point towards the end of my employment in either late September or early October, Mr. Jorgensen actually asked me while we were alone in his office how it felt “to know that everyone wants you" and how it felt “to be so beautiful.” 18. im or about May 2014: a. Mr. Jorgensen had me begin setting up a personal website (www.glennjorgensen.com) for him in early 2014, with practically all of the information about the Smithtown Highway Department, i. On or about May 29, 2014, he took me out to see the paving process so I could take pictures and load them onto the website. ii, When we arrived at the location, in Kings Park, there was a lot of machinery and people working. I took a few photos of the milling process while in the car, but then Mr. Jorgensen pulled over and said we would get out of the vehicle to get better pictures. I was hesitant but agreed. |. As we started to walk over, Mr. Jorgensen made a comment about “giving the boys a treat” by having me at the work site. I gave him a dirty look and before I could say anything he immediately acknowledged with “I'm sorry. I shouldn’t have said that. I'm a guy, I can’t help it.” b. We stopped at a location, upon information and belief, at Atterbury Drive in Smithtown. It is located immediately next to the Smithtown train station where snow was being dumped after it was pulled from the towns. Mr. Jorgensen and I stopped to look at drainage work that was being done. We exited the vehicle and walked over so I could take more pictures for the website. I remember Mr. Jorgensen making a point to say he wouldn’t say anything inappropriate about me getting out of the car this time. The next day, still visibly upset, Mr. Jorgensen asked if he could take me out to lunch, but added, “Not just to make your day better.” I declined with the excuse that I had too much work to do. 19, On or about June 3, 2014, Mr. Jorgensen asked Todd Dwyer, one of the custodians, to take @ picture of him with me. There was no one else around in the office. Mr. Jorgensen explained that he wanted a picture with his personal secretary and that he also wanted to get a photo of him with all of his secretaries at a later time. I had often seen a photo on his desk of him with the original secretaries so the request did not seem too odd, I did feel uncomfortable and I tried to decline several times. I also felt very rushed like he was trying to take it before anyone came back to the office. Page 6 of 1620. Mr. Jorgensen and I were often alone in his office while I checked his email. He would also invite me to come into his office “just to talk” because he needed to vent about issues going on at work like problems he was running into with the road program, his contractor that won the concrete bid, etc. Now that I had been working at the Highway Department for over six months, conversations were becoming more personal when we were alone, He would share things that were going on with his personal life, like his kids, wife, and dad. Mr. Jorgensen would joke that the longer I worked there, the more “dark secrets he would share with me” about his past, This private time also allowed for more conversations like how things were going in my personal life, like the situation with my ex-spouse, my financial situation, current guys I was dating since I was single again, etc. [ was often times told to just “go back tomy ex.” When I stated that I would never, he would press as to why and what went ‘wrong in our relationship, and even asked things like “was the sex at least good?” a. On or about June 16, 2014, while checking Mr. Jorgensen’s email alone with him in his office, he said “If I was 30 years younger I'd be your man.” He would go on later to repeat that statement several more times, also adding that if he was rich, he’d take care of me. I did not know how to respond to those statements and thought it was odd how Mr. Jorgensen seemed to be pushing for me to be dating someone and not single anymore. He would say he “worried about me” and “cared about me,” and that I needed a “good guy to take care of me and my kids.” 21. In or about July 2014, Mr. Jorgensen was showing me the previous year’s photo of all of the Highway Department employees to “find a good guy” for me. He said if he had to pick a man for me from the Highway Department, it would be Brian Tetrault. ‘When I asked why, he explained that Tetrault was good looking, a nice guy, and was probably going to inherit a lot of money some day. My response was that Tetrault is a married man and unavailable, Mr. Jorgensen was always telling me “you should go after that guy” when we were out, especially if he knew someone. He would then go on to explain perks about the person like finances. a. One gentleman Mr. Jorgensen pointed me in the direction of worked at the restaurant Insignia, located at 610 Smithtown Bypass, Smithtown, New York, that was just down the road from the Highway Department. Mr. Jorgensen actually introduced me to him when we stopped at the restaurant after bringing me out to lunch (held at Paces, 325 Nesconset Highway, Hauppauge, New York) with Charles Bartha and Leslie Mitchell from Sydney B. Bowne & Son, LLP, an engineering consulting company. Mr. Jorgensen explained that he needed to stop at Insignia to get gift cards to thank two of the guys that helped make this year’s annual retirement party a success. He told me to come in with him so I could meet the neighbor of one of the other secretaries, Diane McQuade. Mr. Jorgensen proudly introduced me to the hostess, then also to Vince the bartender, whom Mr. Jorgensen seemed to know quite well. Mr. Jorgensen later told me that he had often taken his wife to this restaurant, Page 7 of 16especially since his daughter was dating the owner. I was also introduced to the gentleman Mr. Jorgensen said 1 should date, even though this man’s beautiful wife was in attendance. I did not understand why Mr. Jorgensen was so interested in me finding a man and would usually try and bring the conversation back to work. 22. The alone time in the car when Mr. Jorgensen took me out to Jook at complaints and for driving around, provided the opportunity for personal conversations. Some of the specific locations that we went to: Page 8 of 16 a In or about March 2014, Mr. Jorgensen drove me to the Montclair Yard (a separate location owned by the Highway Department for storing dirt, making mulch, storing “mafia blocks,” dumping street sweepings, etc) where stump grinding was taking place by the company All Island. There were a lot of complaints from the nearby residents because there was a lot of noise while this work was being done. Mr. Jorgensen brought me to see the work and evaluate how many stumps from Hurricane Sandy were left to be destroyed. I had previously been to the Montclair Yard in the beginning of my employment (in or about late Novembes/early December 2013) when Mr. Jorgensen was giving me the “full tour” of the Highway Department, and showed me the screening plant, where dirt was filtered and usable topsoil came out, Mr, Jorgensen also took me to the Kings Park Yard during the tour and introduced me to Ernie Laxton, the Kings Park dispatcher, and Dave Bruckner, the custodian for that office, and a few other employces that happened to be around when we were there. In or about August 2014, Mr. Jorgensen took me to Atterbury Drive, Smithtown, immediately next to train station where snow was being dumped after it was pulled from the towns. Drainage work was completed and this was final inspection because the project affected the Parks Department. When we arrived, Joe Cutillo (last name is upon information and belief) from the Parks Department was already there and Mr. Jorgensen pulled his truck right next to him. The two of them talked for quite a while, discussing work and personal information, and I was sometimes brought into the conversations. i. During this event, Mr. Jorgensen asking me who I was texting, but I ‘was actually just checking my Facebook newsfeed. In or about July/August 2014, I was taken to Bellemeade Ave. off Main St. in Smithtown. Ms. Keegan wanted the sidewalk in front of her business repaired. In or about the Summer 2014, I was taken to a sump I believe by 116 Plymouth Blvd, Smithtown by Washington Blvd. and Morewood. A resident had complained that trees were leaning towards her property from the town’s property and needed to be removed before damage was incurred. Mr. ‘Jorgensen and I got out of the vehicle to walk along the path around the sump‘because it was not visible from the road. I did not understand why I had to get out of the vehicle with him. €. Inor about the Summer 2014, I was taken to 25 Washington Blvd. to look at a curb repair request. It was a small section that was disintegrating and Mr. Jorgensen said it looked like just 2 bad batch of concrete because all the surrounding work still looked great. £. In or about July/August 2014, I was taken to look at curb/apron for Smithtown Chevrolet dealership on Middle Country Rd. g. In or about June/August 2014, I was taken to check a curbing repair request at 49 Arlington Ave., St James. hb. In or about September/October 2014, I was taken to look at the comer house of Lake Ave and Lincoln Ave, Nesconset regarding resident's driveway. Also during same day, we checked the neighbor, 1 Lincoln Ave., Nesconset for a new curb cut. i, In or about the Summer 2014, I was taken to 196 Tredwell Ave., St James because the resident was repeatedly emailing and calling about his flooding problem. We also looked at a house around the block on Northem Blvd for a resident, Danielle Garity, I believe, who recently had work performed by the highway that corrected a puddling issue. 23. One of last breakfasts (in or about September 2014) Mr. Jorgensen took me out to was held at the Lake Grove Diner, 2211 Nesconset Highway, Lake Grove, New York. I was introduced to Rae who lived at 7 Diane Ct. in Nesconset. Mr. Jorgensen said to the waitress, “you met my wife yesterday (they had breakfast there together) and today you get to meet my ‘work wife’.” After we had finished eating, we stopped by Rae’s house to look at the flooding problem she had mentioned. We then looked at a drainage complaint on Gaynor Ave., Nesconset and checked the recently completed paving work on Laura Ct., Nesconset. 24, In or sbout August 2014, Mr. Jorgensen asked what the General Foreman and I were discussing outside, I explained Bob Medwig was trying to help give me suggestions of where I could move. When I told Mr. Jorgensen the suggestion was an apartment complex in St. James, he immediately told me to get in his car and we would go look at it. When we arrived, a fellow highway employee who was not working at the time was outside across the street working on his driveway. Mr. Jorgensen introduced us and inquired about the safety of the apartment complex. Page 9 of 16a, After a few minutes of talking, Mr. Jorgensen and I drove through the apartment complex’s parking lot a briefly looked, and then drove back to the Highway Department. We spoke a lot about my ex-spouse and the reasons I was looking for a new place to live with the kids. He stated to me, “If Arthur (his daughter’s boyfriend) wasn’t in my apartment, I'd rent it to you.” He also began telling me, “If was rich, I'd take care of you.” 25. Any time I finished talking to another male employee, Mr. Jorgensen would always inquire as to what we had been discussing. For example: In or about May 2014 Paul Fette had taken my car for an inspection at Branch Auto Care, Inc., 383 East Jericho Tumpike, Smithtown, New York 11787, while I was at work. When Fette came back to return my keys to me, we discussed the cost of the inspection. Fette noticed Mr. Jorgensen watching us during the conversation. Fette commented “your daddy doesn’t approve of us talking.” Mr. Jorgensen’s attention to Fette and I during the conversation made me nervous. I also felt Mr. Jorgensen was overly protective, possessive and wanted to control whom I interacted with at all times. a. On or about May 21, 2014, Fette again took my car, this time for an oil change. When Fette returned to bring me to pick-up my truck, Mr. Jorgensen was annoyed that 1 was having Fetie drive me instead of me having Mr. Jorgensen drive me. 26.1 became withdrawn from everyone at work, including the other secretaries. They seemed to sce the extra attention I was getting, even though it was unwanted, and had a bit of animosity or jealousy towards me. Mr. Jorgensen’s wife even commented on his behavior towards me at the annual highway retirement party, in August 2014, two different times, In the office, before the group photo of every Highway Department employee was taken, Mr. Jorgensen told me he wanted his wife on one side of him for the photo and that I had better be standing directly on his other side, again joking that 1 was his “work wife.” Mrs. Jorgensen hushed him and advised him to keep his voice down so the other girls in the office did not hear as she did not think that was appropriate. After the main photo was taken, Mr. Jorgensen asked the photographer to get a picture of just him with his wife and I. Mrs, Jorgensen said that Mr. Jorgensen should get a photo with all of the secretaries as to keep things fair and he told her he would, which he did, 27. On or about October 6, 2014, Mr. Jorgensen took me with him to go buy stamps at the St. James Post Office. I needed them to put on his SCHSA mailings for the upcoming event that Mr. Jorgensen would be hosting. He said he needed to eat and I could put the stamps on the envelopes while we were at the diner, but “accidentally forgot” to stop at the Post Office first. While we were at the diner, Mr. Jorgensen told me that his wife loved how each booth had a personal juke box. He also told me they play a game where they scope out the other patrons to find someone that they think the other person would be into sexually. Mr. Jorgensen asked me who I thought he would pick. I did not feel comfortable “playing this game,” but felt pressured to choose when he said, “Come on, there’s only a few people to choose from- just pick.” Page 10 of 16He discussed what he did and didn’t like about the woman I chose, like her hair not being his preference. Mr. Jorgensen then picked someone out for me and it was very awkward for the remainder of the breakfast. Mr. Jorgensen brought up the joke about getting the car door for me, which I again declined. He then drove us to the Post Office where I was brought inside. Mr. Jorgensen had just recently purchased a PO Box for the SCHSA and he wanted to teach me the combination code and how to open the box. Afterwards, we went into the main office and bought stamps. We placed them on the envelopes and got back on line to be introduced to the other ‘woman behind the counter, I believe her name was Mary, who thought I was his daughter. It was apparent Mr. Jorgensen already knew her to some degree, and explained that I was his new “personal, private, secretary.” She told me how lucky I was to work for Mr. Jorgensen. I was later told in the car that she had wanted my position at the Highway Department. The woman then went on to tell Mr. Jorgensen how lucky he was to have me working for him. Seeing as how she had only just met me and knew nothing about me, it seemed obvious she was referring to my youth and looks. Again, I felt flaunted and shown off, and that meeting the other Post Office clerk was not necessary, nor was the way I was introduced. a, After leaving the Post Office, Mr. Jorgensen asked if 1 had brought any complaint addresses with me, which I was not prepared and did not. We drove around a bit and ended up at the house of someone he knew personally, a famous poker player, Will “The Thrill” Failla. I got the uncomfortable introduction and it was explained that I could be fired at any moment by him. T enjoyed speaking with Mr. Failla’s expecting girlfriend as Mr. Jorgensen and ‘Mr. Failla spoke some politics. I believe Vincent Puleo was called on Mr. Jorgensen’s phone and they discussed boat slips. b. The visit Iasted about a half hour, and then we departed to go back to the office. As we were driving back to the office, Mr. Jorgensen noticed dog drool had gotten on his pants from the two dogs at the Failla residence and that the white stains were quite noticeable. A joke was made that it could be misconstrued as something else, especially since we were alone and had been ‘gone away from the office for so long, I asked him to go home and change his pants because I did not need anyone thinking that I was doing anything of the sort with him, but Mr. Jorgensen laughed and said that no one would actually think that, 28. Working conditions became very strained a few days after the October 6, 2014 incident. Mr. Jorgensen had been asking me more questions about the guy I had been dating for the past few months, but I continued to be vague and did not tell him much. ‘Mr. Jorgensen had often pressed for more information, and on Oct 10, 2014, I decided it would be respectful to let him know that I was dating one of the Highway Department employees since things were becoming more serious between us. I was nervous of his reaction and Mr. Jorgensen saw I was hesitant, He told me he would share one of his “secrets” from his past and shared a story about a sexual encounter from when he was younger, I suppose in a hope to make me feel like my secret of Page 11 of 16who I was dating would be safe with him. When I told Mr. Jorgensen I was dating someone from the Highway Department, he immediately asked if it was “the guy in the back,” referring to Dominick Acquista. I replied that it was. There was a pause in the conversation as Mr. Jorgensen took a few drags on his cigarette while thinking about it, then said, “good for you.” He asked a few questions like how long it had been going on. Mr. Jorgensen asked if I had sex with him yet, and after seeing I did not feel comfortable answering he assumed, “Ok, so you've slept with him.” He repeated “good for you” a few more times during the questioning and the conversation ended and I went back inside to get ready to go home as it was the end of the work day. 29. When we retumed to work the following Tuesday, October 14, 2014, after the Holiday weekend, Mr. Jorgensen’s tone had changed about my dating Dominick Acquista. He seemed annoyed and distracted much of the morning, and eventually demanded I go into his office so we could talk alone. Mr. Jorgensen was upset and asked a few more questions about my dating life. Mr. Jorgensen then said a. few negative things about Dominick Acquista like, “He has e reputation you know,” “You have to think about what's best for your kids,” and that Dominick [Acquista] “is going to break your heart.” The rest of the day Mr. Jorgensen was angry towards me and told me several times that he “was so mad at me.” After the first few times of him saying this I asked as to why specifically and he replied, “You know why,” and walked away. It was difficult getting through the work day. 30. The following day, October 15, 2014, Mr. Jorgensen again called me into his office and told me that he talked to his wife about the whole situation. He seemed calmer about everything. He shared that his wife said there was nothing he could do about when two people like each other and told him to just make sure the next secretary he hired was married. He then went on to tell me a story about a night that be and his wife were out to dinner when someone he knew approached them. The person apparently told Mr. Jorgensen how lucky he was to have such 2 good looking secretary, no offense to his wife. She replied, “Don’t worry, I reap the benefits.” When I asked Mr. Jorgensen if he meant that sexually, he looked away and laughed, saying that “he’s a guy and can’t help it.” a. immediately told him how wrong that was, and even worse that he told me. I left his office in disgust. b. Later that day I was called into Mr. Jorgensen’s office “just to talk,” and the topic of my dating life inevitably came back up. Mr. Jorgensen again seemed upset with me. He even told me I should ‘just forgive my ex-spouse, go back to him, and marry the guy.” One of the employees from the office, Louis Varialle, noticed that something at work was bothering and upsetting me and asked if everything was ok. Page 12 of 1631. On or about Thursday Oct 16, 2014, and Mr. Jorgensen was hosting the SCHSA at Butterfield’s in Hauppauge. All of his secretaries were invited to this event. Brynne Blohm and J traveled together in Mr. Jorgensen’s car to arrive before anyone else, JoAnn Anasa drove herself, and Joanne Dellasperanza and Diane McQuade arrived with the deputy, Mr. Murphy. Page 13 of 16 I stayed at the entrance to greet everyone as they came in and have them sign in, and the rest of the secretaries socialized. Mr. Jorgensen spent almost the entire time next to me at the front door, still bantering with me over my relationship. He repeatedly told me that he “felt hurt.” i, Mr. Jorgensen also said more than once, “I'm so mad at you right now. I should fire you and transfer Dominick [Acquista].” I understood this to mean that Mr. Jorgensen wanted to transfer Dominick to the Kings Park Highway yard located on Old Northport Road, Kings Park, New York. ii. Mr. Jorgensen went on to tell me that he would at least give me a few months notice so 1 could line up another job because he understood I was a single mom and still “cared about me.” Mr. Jorgensen said many times that our arguing felt like “a relationship spat.” By the end of the event, I was so annoyed with him and felt very drained after being harassed over this for almost a whole week. The other secretaries left early and went back to the office in Mr. Murphy's car, including Brynne Blohm, who had originally travelled to the event with me. When Mr. Jorgensen and I were on our way back to the office, he had to stop at 7-11 to get to an ATM to give me back $20 that I lent him as a tip for one of the waitresses, Directly across the street was the restaurant Insignia. After leaving 7-11, Mr. Jorgensen pulled into the restaurant parking lot and invited me inside with no explanation. Being that I was in dite need of a restroom, I agreed to go in, We greeted the hostess and I immediately asked for the bathroom. When I came out, Mr. Jorgensen was speaking with Vince the bar tender. I saw that he had a drink poured and took a sip. Mr. Jorgensen asked if I wanted anything and I politely declined. The hostess came over to talk to Mr, Jorgensen and asked what brought him in, to which he responded that we were just passing by and then asked me to take a picture of him with the hostess. I agreed and after two pictures, I helped Mr. Jorgensen send the picture via text message to the other secretary, Diane. We said goodbye to her and a few other employees and then drove back to the office. When I started to get out of the vehicle, he asked me to wait because he still had more be wanted to discuss with me. The same talk of how upset he was, how hurt he felt, how angry he was, how bad Dominick was for me, and the threats of firing me and transferring Dominick came up. It was nearing the end of the work day and there were many Highway Department employeeswalking around the yard and could see us sitting in Mr. Jorgensen’s truck talking. One gentleman, William Burke, even came over to say hi, and saw that I was not comfortable in the truck and that something was wrong. A few minutes more of what felt like being scolded for dating someone, I asked if I could leave the vehicle to which he allowed and immediately followed me into the building. A few minutes after leaving for the night, while driving home, I received a text message from Mr. Jorgensen ordering me not to tell anyone about what had been going on or what had been said, 32. On the morning of October 17, 2014, Mr. Jorgensen was still visibly upset with me and was being curt with me all morning. He asked at one point, “Aren’t you going to look at me?” I had not even realized that 1 was avoiding eye contact with him all morning. Page 14 of 16 a ‘After Mr. Jorgensen left the office, Lou Varialle came over to me because he saw that something was still bothering me and asked if it had to do with Mr. Jorgensen. I replied yes, and told him that Mr. Jorgensen was even bothering ‘me during non working hours by sending me a text, though I do not believe I gave out the exact contents of the text message. A little while later, Mr. Jorgensen returned to the office and I started having, him sign some work. He suddenly stopped and demanded I get in his office. I told him I could not at that moment because I was watching the phones while Brynne Blohm was out having a cigarette. He told me he did not care and that the residents could wait, and demanded again that I follow him into his office. When we sat down, Mr. Jorgensen asked if I told Lou that he had texted me. When I said I did, Mr. Jorgensen told me that he “could not trust me,” and that 1 “was out to hurt him.” Aggravated by the entire week, I asked Mr. Jorgensen when my last day of employment would be, to which he pointed down at his desk and said, “right now.” I immediately stood up and began walking out. Mr. Jorgensen immediately said, “Are you going to take me to court for sexual harassment?” I stopped, tumed back and said, “I don’t work for you anymore. What I do or don’t do is none of your business,” and walked out of his office to start packing my desk. Mr. Jorgensen was hovering over me as I was clearing out my stuff and I asked him if he was going to watch me the whole time. He replied that he was because he didn’t trust me. ‘The next few minutes were silent as I continued to gather my things. Mr. Jorgensen then asked, “Should I get e lawyer?” I do not remember if I responded or not, but I think I said he should do whatever he felt necessary. Mr. Jorgensen followed me to the front office as I left to put the stuff in my car. I returned to grab a few things from the kitchen and then used the new hand scanner to punch out. went unescorted back to the dispatcher’s office toIv. Due to punch out. When I came back through the main office, Mr. Jorgensen mumbled to me as I passed by that I was a good employee and thanked me for my. hard work. 33. A few hours after leaving the employment of the Town, I went to the Public Safety Office in Smithtown to report the sexual harassment. 34, The next day, Saturday October 18, 2014, and again on October 19, 2014, Mr. Jorgensen tried calling me. When I did not answer he sent me a text offering my job back. I did not respond to Mr. Jorgensen, as Public Safety had advised me not to be in contact with Mr. Jorgensen. 35. On Monday, October 20, 2014, Mr. Jorgensen again tried calling me without leaving a message. After finally hearing back from Public Safety, I was advised to send Mr. Jorgensen a text instructing him to stop trying to contact me. 1 complied with the directive of Public Safety. 36. On Tuesday, October 21, 2014, my Aunt Kelly-Ann Hughes called me asking if I was still employed by the town. She mentioned that her father-in-law Bill Majuk (the campaign manager to Mr, Jorgensen) called her and told her I quit, but that she wanted to hear my side of what happened. After I explained everything that I had been going through, she told me that she had to call Bill back and would tell him I ‘was not interested in taking the job back. When I asked her what she meant, she said that Bill had told her to call me and offer my job back if I drop the harassment case. I asked my aunt to not tell him anything and stay out of it. I also suggested to her to tell Bill that if anyone needs to get in touch with me, they can do so by contacting Public Safety. My aunt told me that she would just tell Bill that she didn’t reach me and just left a message. Public Saftey was made aware of this contact between Bill Majuk and my Aunt. Describe the damage and injuries suffered. the discrimination based upon sexual harassment and hostile work environment, I have been wrongfully terminated, subjected to emotional harm, and denied benefits. v. A description of the total damages sought. Tam seeking damages in the amount of $200,000.00, and any and all benefits to which I was entitled plus compensation for any losses I have incurred, and to be reimbursed for any therapy to which I need due to the ongoing and pervasive sexual harassment and hostile work environment. Page 15 of 16Thave read the foregoing, and swear under the penalties of perjury that the forgoing statements are true and accurate to claimant’s own knowledge, except as to the matters therein stated to be alleged upon information and belief; and as to those matters deponent believes them to be true, 12/5 [2014 AIMEE L DATE 47 Grand Avenue Shirley, New York 11967 STATE OF NEW YORK ) )ssz COUNTY OF SUFFOLK ) On the 5” day of December in the year 2014 before me, the undersigned, personally appeared AIMEE LYNN SMITH proved to me on the basis of personally known to me or proved to me on the basis of satisfactory evidence to be the individual(s) whose name(s) is (are) subscribed to the within instrument and acknowledged to me that he/she/they execuied the same in his/her/their capacity(ies), and that by hisher/their signature(s) on the instrument, the individual(s), or the person upon behalf of which the individual(s) acted, executed the instrument. (Gignature and office of individual taking acknowledgment) xopew nen ee ert Ne So Corey conenesen Ex: Foor 2002 Page 16 of 16