Retum date: June 19, 2016 SAMANTHA MENH. Superior Court Plaintiff, Judicial District of Stamford-Norwalk at Stamford 7 May 26, 2016 -against- : cv- as : COMPLAINT AUGUST WOLF, BAYLOR MYERS and AUGUST WOLF FOR SENATE (Campaign) Nature of the Action 1, This is an action for breach of contract, breach of the duty of good faith and fair dealing, and wrongful discharge. ‘The Parties Plaintiff Samantha Menh (hereafter, “plaintiff") is a political consultant who was hired and engaged by August Wolf (hereafter “Wolf”) and by August Wolf for Senate (hereafter, the Campaign”) (collectively referred to as “Defendants”) as a Senior Advisor and Finance Director, in order to assist Wolf in his effort to secure the nomination to become the Republican nominee for United States Senator from Connecticut, to run against Richard Blumenthal for the seat he presently occupies as the senior United States Senator from Connecticut. During all relevant times herein, she resided at Beacon Harbor Point Road, 1 Harbor Point Road, Apartment 207, Stamford, CT 06902. 3. Defendant Wolf is a resident of Connecticut and lives at 88 Maple Tree Ave unit C, Stamford, CT 06906. He is running for the United States Senate against incumbent, Richard Blumenthal,4. Wolf employed plaintiff through the August Wolf Campaign on or about March 18, 2016, and in so doing made certain contractual promises. 5. Baylor Myers has been residing at 88 Maple Tree Ave., unit C, Stamford, CT 06906. Jurisdiction 6. Jurisdiction is appropriate in this Court because Plaintiff was employed in the Campaign’s Stamford, CT office, resided during all relevant times herein in Stamford, and it is there that the contractual and employment relationship was based between the parties. Additionally, Plaintiff has suffered injury in Connecticut by virtue of defendants’ conduct described herein. Moreover, Wolf resides in Stamford, and the Campaign’s offices are located in Stamford. Factual Allegations 7. Plaintiff is an experienced political consultant for Republican candidates who was fully engaged elsewhere when she was asked to work on Wolf's campaign, which was already in trouble, Specifically, by the 1 plaintiff joined the campaign, Connecticut newspapers were reporting the following: + The troubled U.S. Senate campaign of Republican August Wolf is without a campaign ‘manager and spokesman for the second time in two months, but the Stamford businessman said Tuesday he is staying in the race and will announce a new team next week. + His first campaign manager, Tom Daly, quit last fall after Wolf's fundraising fell flat. A team of former interns was given control of the campaign, but they departed in a flurry of firings and resignations two months ago alleging a hostile work environment.+ Wolf's campaign failed to file an end-of-year report with the Federal Election Commission, but a recently hired campaign consultant, Matt Wylie, says a recently filed report will show the campaign ended the year with about $140,000. + Wylie, who was the director of former U.S. Rep. Chris Shays’ unsuccessful 2012 campaign for the GOP U.S. Senate nomination, which was won by Linda McMahon, Joined the campaign as a general consultant. + Wolf said he failed to file an end-of-year finance report in January, which has brought the threat of sanctions from the Federal Election Commission, because of concems about the performance of Matthew R. MacFarlane, Troy Meeker and Michael Napoli + MacFarlane, 22, was both campaign manager and treasurer when fired on January 24, 2016. Meeker, also 22, was a communication director eventually named as co-manager. Napoli, 21, was a field director. All three left the campaign in late January 2016, saying Wolf was abusive. . Republicans have been seeking an alternative. Dan Carter, a state representative from Bethel, is weighing a run, as is Jack Orchulli, the GOP nominee in 2004. Joe Visconti, a former West Hartford councilman, has an exploratory committee. 8. Because of the tumultuous history of the Campaign, plaintiff sought and secured a promise that she would receive at least $50,000 in compensation if she disrupted her work on. behalf of other groups and candidates to work for Wolf and his Campaign. 9, Plaintiff was also promised as a commission of 5% of all monies raised. 10. After plaintiff joined the Campaign, she immediately began noticing that candidate Wolf engaged in sexually improper and abusive behavior and that he was not abiding by federal and states laws regarding financial reporting and seeking signatures on his petition. His inappropriate sexual comments and behavior were severe and pervasive. Plaintiff is a young lady in her mid twenties. Wolf is in his fifties. 11. Amongst the many examples of his sexually harassing conduet were these:c Wolf repeatedly called plaintiff, “babe” and she invariably corrected him and reminded him that her name was Samantha. When plaintiff first joined the campaign and was talking to Wolf about his interests she asked him what he did for fun and he responded, “I have sex!” His mind always in the gutter, one time Wolf asked plaintiff whether she was sleeping with the campaign manager. Wolf asked plaintiff is she “has ever been sexually satisfied by a real man?” Wolf reminded plaintiff that she was staying in an apartment paid for by the Campaign and that he could get into her apartment at any time, He dangled and waved her apartment keys in front of her face, while he said “I know who comes in and out of your apartment because I have the keys!” Wolf made inappropriate comments like “When I am in the U.S. Senate, someone should put a taser on my dick so I can stay awake. While Campaign staff members were driving to a fundraising event with Wolf in the backseat with his girlfriend, the two of them were groping each other and making out, and he then put the girlfriend’s head in his lap. Wolf constantly was touching the plaintiff, which she felt was creepy, and she continuously told him, “don’t touch me.” On plaintiff's last day of work, the Wolf barricaded plaintiff in her office with his 6°6” body and would not let her walk out of the room. Plaintiff'is 5"2” young lady and repeatedly asked Wolf to let her leave the room as she felt unsafe with him in there. He would not let her leave, so she got on her cell phone and made a call to report what was going on contemporaneously so that he would realize that someone‘on the outside world would be a witness to his inappropriate and unprofessional conduct. j. Wolf used highly sexualized and offensive language, referring to his former staffers as “just a bunch of gay lovers circle jerking each other.” Kk. Given that the tone is set from the top down in organizations, soon Wolf's campaign ‘manager, Baylor Myers, started to join in, making highly inappropriate comments. For instance, Baylor Myers called plaintiff a “woman of the night,” said he loved her, that he wished he could wake up with her, and he continuously asked plaintiff out on a date. Baylor texted her that she was “a beautiful distraction.” One time he texted her “Sleepover?” to which plaintiff responded “Are you out of your mind?” He also made highly offensive racist remarks about African Americans. 1. Both Wolf and campaign manager, Baylor Myers, disrespeetfully and obscenely referred to the Connecticut Republican House minority leader, Themis Klaridis as litoris, m. On one occasion when Wolf, his girlfriend Jessica, and the campaign manager and plaintiff were going out to dinner to discuss how to involve Jessica in the campaign, Wolf lasciviously asked plaintiff, “But the question is, .who is going to end up with who at the end of the night?” 12. While out campaigning and meeting the Town of Westbrook’s Republican Town committee members, he engaged in inappropriate behavior by grabbing a waitress behind the bar in plain sight of the Westbrook RTC members. 13, Almost every word that came out of Wolf's mouth was intended to prove his sexuality and that he is not gay. Wolf's father was openly gay, as is Wolf's sister, Erika.14. Inhis effort to prove that he is not gay, but reflecting his insecurity and obsession with the topic, he subjected his former communication's director, Troy Meeker, who is gay, to ‘unwanted comments, speculation and questions about his sexuality. He would casually hypothesize with Mecker’s work colleagues about Meeker’s potential relationships. This abusive homophobic talk was one of the reasons that Mecker quit the Campaign, 15, Exhibiting signs of arrested development and sexual insecurity, Wolf constantly talked about sex and his penis and the penis size of others, creating a hostile environment for the campaign workers. 16. When Connecticut state Republicans became aware of his inappropriate conduct, they looked for another candidate for Senate, and found one in the person of Dan Carter. 17. Exhibiting puerile behavior, Wolf began referring to Carter as “Dan the dough boy” because he is chubby, in front of an overweight campaign worker who felt those comments about looks and weight were unprofessional and demeaning to overweight people. Wolfs "unprofessionalism permeated the atmosphere of campaign headquarters. 18. Wolf even made inappropriate comments about incumbent Dick Blumenthal, capitalizing on the fact that the Senator's first name is also a nickname for a body part, and using that word with a size reference whenever he disrespectfully referred to the Senator. 19. Plaintiff objected to the pervasive use of sexually charged language in the workplace and complained to Wolf and the campaign manager about Wolfs inappropriate sexual conduct, and Jet them both know how uncomfortable she felt with his puerile sexual references, harassment and conduct. She told him that he had created an intolerable sexually hostile work environment, 20. Thereafter, Wolf retaliated against plaintiff, as described further below.21, Inaddition to Wolf’s improper conduct in creating a sexually hostile working environment, he and his campaign also were involved in a pattern of repeated financial impropricties and violations of state and federal election campaign laws. 22. Wolf was late with his FEC ing, and was fined by the FEC. 23. Wolf and his campaign illegally coordinated strategy with Super PACs. When plaintiff learned of that knowing violation, she complained about it to defendants. In response, they were angry at her for being a squeaky wheel and a whistle blower, and retaliated against her, as set forth in more detail below. 24. Under the law, a campaign can fundraise for three different stages: the primary, the convention, and the general up to a total amount of $8,100. ‘The funds must remain separate, however. Defendants improperly tapped into one fund to use for the other and overspent by approximately $40,000. When the Treasurer at Red Curve discovered what defendants had done, defendants tried to cover it up by having Wolf take money from his personal funds and provide it to the Campaign in order to cover up the illegal use of funds from the Primary Account to make up the difference in the Convention account. Plaintiff told defendants that they were putting the campaign in a compromising position and plaintiff did not want to be part of any skirting of laws and rules. 25. For instance, when the Republican party endorsed Dan Carter (after he entered the race just the month before) as its candidate for the U.S. Senate instead of Wolf (who had been the sole Republican candidate for over a year), Wolf was entitled to still try to force a primary by gathering petition signatures from 2 percent of registered Connecticut Republicans. 26. However, there are certain state laws that apply with respect to gathering signatures on a jon, and defendants knowingly violated those laws. For instance, the state law requires that aConnecticut registered Republican accompany the petitioner as a witness to the signatures. Defendants purposefully violated that law. When plaintiff learned of that knowing violation, she complained about it to defendants. In response, they were angry at her for being a squeaky wheel and a whistle blower, and retaliated against her, as set forth in more detail below. 27. Plaintiff told the campaign manager that she received a call from the Campaign’s petition vendor, Scott, alerting her that two of his workers were out collecting signatures without a witness and they were upset there was no witness made available. Baylor, the campaign manager, cursed and complained that the vendor had provided that information to plaintiff. He asserted that there ‘was a loose interpretation of the laws regarding witnesses and plaintiff should not involve herself with such compliance issues. Plaintiff responded that the vendor is not calling Baylor the campaign ‘manager because he does not trust his opinion. 28. Plaintif'texted both the candidate and the campaign manager, stating that she was not comfortable with their loose interpretation of the law. Later that same day, Wolf blockaded plaintiff in an office with his body blocking the door. Plaintiff'stated that she wanted to talk to seek legal advice about what he was doing. Wolf insisted that she give him her computer so that plaintiff could not use what was on there as evidence. Plaintiff, who is 5°2”, was physically intimidated by 6°6” Wolf, who was physically blocking her e: ‘it and bat ding her in her office. Plaintiff then realized she could not work there any more under such hostile, illegal and physically intimidating circumstances. 29. Amongst the retaliatory behavior, Wolf and his campaign manager at his direction would isolate and not speak to plaintiff. Defendants shut her out of all necessary meetings and strategy discussions, so that she was unable to do her job. Wolf avoided fundraising with plaintiff, thereby preventing her from receiving the commissions that he had contracted to pay her. They started leaving plaintiff out of all senior team discussions in which she was previously included.Wolf stated to plaintiff, “you are just here because you have a contract and you get paid anyway.” On one occasion, while plaintiff was driving Wolf in the Campaign’s vehicle from a Republican Town Committee visit, Wolf screamed at her in her face for ten minutes while she was driving on a highway. 30. Wolf told plaintiff that he would ruin her career if she ever though about leaving and he ‘would ensure that she would never survive in a political career after she left the Campaign. 31 Give the sexually harassing and hostile work environment, the illegal fundraising, the illegal petition drives, the violation of campaign finance laws, and the retaliation, the atmosphere of the workplace was so severely and pervasively hostile that no reasonable person could continue to work there. As a consequence, plaintiff was in effect constructively discharged and left the Campaign on May 18, 2016. FIRST CLAIM FOR RELIEF (WRONGFUL DISCHARGE) 32. Plaintiff repeats the allegations in paragraphs 1-30 above as though fully set forth herein. 33. Sexual harassment is a violation of public policies under federal law (as set forth both Title VI) and Connecticut’s state labor laws. 34, Defendants’ violations of federal and state campaign finance laws, and state petition laws constitutes a violation of public policy. 35. Plaintiff complained about sexual harassment and the defendants’ violations of federal and state campaign finance laws, and state petition laws and as a result, was retaliated against and constructively discharged.SECOND CLAIM FOR RELIEF (BREACH OF THE COVENANT OF GOOD FAITH AND FAIR DEALING) 36. Plaintiff repeats the allegations in paragraphs 1-30 above as though fully set forth herein. 37. The agreement between the parties was contractual in nature, and was entered in Conneticut. 38. As a matter of law, every Connecticut contract contains an implied covenant of good faith and fair dealing. 39. Defendants repeatedly breached the covenant of good faith and fair dealing in their dealings with plaintiff, and she was damaged thereby. 40. Plaintiff is entitled to an award of such damages flowing from this breach of the covenant of good faith and fair dealing as may be found at trial, 41. Plaintiff has suffered emotional distress, incurred costs and fees and lost business opportunities, as a result of such conduct, and has been damaged by Defendants’ conduct, 42. Plaintiff is entitled to an award of such compensatory and punitive damages flowing from such conduct, as may be found at trial. THIRD CLAIM FOR RELIEF (TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS) 43. Plaintiff repeats the allegations in paragraphs 1-30 above, as though fully set forth herein. 44. The agreement between defendants and plaintiff was contractual in nature and entered in Connecticut. All services to be rendered were (o be rendered in Connecticut, pursuant to Connecticut and federal law. 45. Despite knowing that cutting plaintiff out of all strategy meetings and discussions, and refusing to fundraise with her, would would interfere with Plaintif?’s ability to eamcommissions and with her contractual relations, defendants, with malice and intent, tortiously interfered with Plaintiff's contractual relations with Carling. 46. Plaintiff has suffered emotional distress, incurred costs and fees and lost business opportunities, as a result of such conduet, and has been damaged by Defendants’ conduct. 47. PlaintifV'is entitled to an award of such damages flowing from this tortious interference as may be found at trial, FOURTH CLAIM FOR RELIEF (BREACH OF CONTRACT) 48. Plaintiff repeats the allegations in paragraphs 1-30 above, as though fully set forth herein. 49, The parties had a contract in which plaintiff was guaranteed a minimum of $50,000, if she left her employment and came to work for the defendants. 50. Plaintiff did so, and went to work for defendants. 51. The parties had a contract in which plaintiff was entitled to 5% of all commissions. Defendants engaged in such bad faith conduct as to interfere with plaintiff's ability to earn commissions. 52. Defendants’ bad faith conduct, and failure to pay plaintiff’ a minimum of $50,000 and to pay commissions is a breach of the parties” agreement. 53. Plaintiff is entitled to an award of such damages flowing from this breach as may be found at trial. WHEREFORE, plaintiff prays for judgment as follows: (a) On the First Claim for Relief, for $160,000 in compensatory damages, $2,000,000 in punitive damages, attomeys fees and costs, together with prejudgment interest, (b) On the Second Claim for Relief, for $160,000 in damages and such punitive damages as95/27/2016 69:25 2825433790 2ND STEET PAGE 02/02 ‘may be found at trial. (©) On the Third Claim for Relief, for $160,000 in damages and such punitive damages as may be found at tra . (4) On the Fourth Claim for Relief, for $160,000 in compensatory damages for breach of contract, together with prejudgment interest Together withthe costs of this action, and such other and further relief as may seem just to the Court. Respectfully suominted, PLAINTIFF Ave. Suite 201 Norwalk, CT, 05851 VERIFICATION |, Samantha Menh, d- hereby verify and swear that the above is true and correct to the best of any knowledge and be ief, SZ ZINAN 9 S137 | lp ime Samantha Menh