SUMMONS - CIVIL

JD-CV~l Fe·i.6-11 _ C.G.S. §§ 5.'1- 46,51-347,51-349, 51-350,52-45a, 52-48, .52-259,-· P.B. Sees. 3-1 throuqh 3-21,8-1

STATE OF CONNECTICUT

SUPERIOR COURT
www.jud.ct.gov
interest interest

See page

2 for instructions

o o ".X" o o

"X" if amount,

legal interest costs is less than $2,500. if amount, legal interest costs is $2,500 or more. other

or property or property

in demand, in demand,

not including not including

and and

TO: Any proper STATE commanded this Summons

officer;

BY AUTHORITY

OF THE of

OF CONNECTICUT, to make and attached

you are hereby Complaint.

due and legal service

"X" if claiming

relief in addition

to or in lieu of money

or damages. Telephone number of clerk (With area code)

Address of court clerk where writ and other papers shall be filed (Number, street, town and zip code) (C.G.S. §§ 51-346, 51-350)

Return Date

(Must be

Tuesday)

95 Washington
[RJJUdiCial District Housing Session

Street,

Hartord,

CT
G.A.

06106

0 Number:
Esq,

(860
Hart

) 548·2700

06

Month

28 , 2 011
Year

A. (Town in Which writ is. returnable) (C.G.S. §§ 51-346, 51-349) t

or

Case type code (See list on page 2)

Major:

Minor:

90

For the Plaintiff(s)

John Kardaras,

please enter the appearance of: 124

Jefferson Street, Hartford, CT

Name and address of attorney, law firm Dr plaintiff if self-represented (Number, street, to,VlI and zip code) Telephone number (with area code)

I Juris nomber
402742

(to be ent.red by allorneyon/y)

I Signature of Plaintiff (If self-represented)

3

06106

(860 ) 527-9611
Number of Plaintiffs: Parties First Plaintiff Additional Plaintiff First Defendant Additional Defendant Additional Defendant Additional Defendant

1
Name

I Number

of Defendants:

(Last, First; Middle fnitiaf) and Address Bloomfield,

of Each party (Number; Street; P.O, Box; Town; State; Zip; Country, if not USA) P-01 CT

Form JO-CV-2

attached

for additional

parties

Name: Edwards, Wille Address; 60 Brookline Avenue, Name: Address: Name: Ci~ Address: CI of Hartford John Bazzano,

06002
P-02

0·50 Town Clerk, City Of Hartford,

550

Main

Street,

Hartford,

CT

06105
0-51

Name: Ortiz, Charlie Address: 760 Prospect Name: Mr Pedro Address: Name: Address:

Street,

Hartford,

CT

06103
0-52

Segarra

0-53

Notice to Each Defendant

1. YOU ARE BEING SUED. This paper is a Summons in a lawsuit. The complaint attached to these papers states the claims that each plaintiff is. making against you in 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, YOLI 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 at www.jud.ct.gov under "Court Forms." 4. If you 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 all-line at www.jud.ctgov under "Court Rules." 5, If you have questions about the Summons and Complaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on Ie al uestions, ._..... Name of Person Signing at Left Date Signed ~ Commissioner of the Superior court John Kardaras 5-27-11 Assistant Clerk

Iftlli;f.Jummons is signed by a Clerk: a. e signing has been done so thatthe Piaintiff(s) will not be denied access to the courts. b. It is the 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. Tile Clerk signing this Summons at tile request of the Plaintiff(s) is not responsible in any way 'for any errors or omissions in the Summons, any atleqations contained in the Complaint, or the service of the Summons or Complaint.

For Court Use Only File Date

I certify I have
understand

read and

Signed (Sjr/f-RftP,I~esented Plaintiff)

the above:

amount of $250

----

[RJ Commissioner of the. Superior Court Assistant Clerk

(Page 1 of 2)

RETURN DATE: JUNE 28,2011 WILLIE EDW .. RDS A VS TBE CITY OF HARTFORD, ET AL

:SUPERIOR COURT :J. D. OF HARTFORD :ATHARTFORD MAY 27,2011

COJ.V[PLAINT COUNT ONE: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS AS TO THE CITY OF HARTFORD 1. At all times mentioned herein, the defendant, The City of Hartford has been a municipal corporation existing under the laws of the State of Connecticut. 2. At all times mentioned herein, Pedro E. Segerra, was the Mayor ofthe City of Hartford. 1. At all times herein, Stewart Issac, is a Supervisor far the Department of Public Works, an Department of the City of Hartford. 4. At all times herein Kevin Burnham is the Director of the Department of Public Works, an Agency of the City of Hartford. 5. At all times herein, The Plaintiff, Willie Edwards was an employee of the City of Hartford, Department of Public works. 6. At all times herein, Charlie Ortiz, is a resident of the City of Hartford and spouse of Pedro Segarra, Mayor of The City of Hartford.

7. On or about October, 14,2010, The Plaintiff Willie Edwards, was working at his position, at the Hartford Transfer Station. S. On or about that day, Mr. Charlie Ortiz, came to the Transfer Station and Attempted to dump leaves and other debris. At the time and place, Willie Edwards, in capacity as an employee of the City of Hartford, identified Mr. 011iz as a resident of the City of Hartford and requested that he present his permit, in order to use the transfer station. Mr. Ortiz indicated that he did 110thave a permit and requested that he be permitted to dump without a permit. Willie Edwards, explained that he was following the Regulations of the City of Hartford and that Mr. Ortiz was required to obtain a permit.
Mr. Edwards further explained to Mr. Ortiz, how to obtain said permit. 9.

MT. 011iz persisted in insisting that he be permitted to use the Transfer Station,
notwithstanding that he did have a permit. At one point Mr. Ortiz exclaimed "Do you lmow who I am" and further stated "I will make a call and fix that". M1'.Edwards observed Mr. Ortiz making a call, before Mr. Ortiz returned with a permit to use the Transfer Station.

10. On or about October 16, 2010, as Mr. Edwards returned to work, he was directed to meet his Supervisor, Stewart Issac. Mr. Issac stated to Mr. Edwards "you refused two guys in a red truck on Thursday, you (explicative deleted) ... Was it one of these guys" Mr. Isaac then showed Mr. Edwards a photograph of Mr. Ortiz and Mayor Segarra. M1'.Edwards indicated that Mr. Ortiz was the man in the photo. Mr. Issac indicated that Mr. Ortiz was the Mayors spouse and told Mr. Edwards that he was transferred

from is position at the Transfer Station, pending an "investigation".

My. Edwards

was given no further information other than he "messed up" and that he was in trouble with his position because he had refused to allow the mayors spouse to use the Transfer Station, On about November 5, 2010 Mr. Edwards suffered a stroke.

II, The hereinafter stated injuries and damages to the plaintiff, Willie Edwards were caused by the carelessness and negligence of Defendant, The City of Hartford, its agents servants or employees in one or more of the following ways: (a) in that the Mr. Edwards was placed in fear 'of losing his postion for following regulations; (b) In that Mr. Edwards was not informed as to the nature ofthe complaint against preventing him from adaquely defending himself him while he was transferred from his position and 1 in fear of being terminated. eft 12. As a direct and proximate result of the carelessness and negligence of the Defendant the Plaintiff suffered and sustained the. following injuries, some, or all, of which injuries may be permanent and partially disabling and/or pre-existing condition: (a) Stress; (b) Stroke; (c) Physical impairment, loss of enjoyment of life. (d) An aggravation of pre-existing conditions; (e) great physical pain and suffering;
811

aggravation ofa

(f) and a shock to the nervous system. 13. As a further result of the carelessness of the Defendant, the Plaintiff has incurred and will be obligated to expend large sums of money for hospital, medical care, x-rays, therapy, medication and the like in an effort to cure himself.

COUNT TWO NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS AS TO CHARLIE ORTIZ 1.-10. Paragraphs one through ten of Count One are hereby made paragraphs one though ten of this count.
11.

The hereinafter stated injuries and damages to the plaintiff, Willie Edwards were caused

by the carelessness and negligence of Defendant, Charlie Ortiz one or more of the following ways: (a) Mr. Charlie Ortiz called his spouse to intervene on his behalf and complained that he did not get preferential treatment as the spouse of the mayor (b) Mr. Ortiz complaint was without merit and he knew or should have known that Mr. Edwards' would face repercussions because of his actions. 12-13 Paragraphs twelve and thirteen of the First Count are hereby made paragraphs twelve and thirteen of this count.

COUNT THREE NEGLIGENT PEDRO SEGARRA

INFLICTION

OF EIVIOTIONAL DISTRESS AS TO

1.-10. Paragraphs one through ten of Count One are hereby made paragraphs one though ten of this count. 11. Mr. Pedro Segarra personally intervened in the matter causing the Department of Public Works to take action against Mr. Edwards.
12.

Mr. Segarra's actions were not within the scope and duties of the Office of the Mayor.

13.

The.injuries suffered by the plaintiff were the result of negligence ofthe defendant Pedro Segarra, in that: (a) He knew or should have known that the Department.Heads and Supervisors would take action against Mr. Edwards when the Mayor intervened on behalf of his spouse; and (b) Mr Segarras actions placed Mr. Edwards in fear of losing his position for following regulations; (c) That the Mayor violated ethics rules and regulations then in place by intervening on behalf oOris spouse when he should have rec1used himslf thereby creating a conflict of interest.

14-15. Paragraphs twelve and thirteen are made paragraphs fourteen and fifteen of this count.

COUNT

FOUR INTENTIONAL

INFLICTION OF EMOTIONAL

DISTRESS AS TO

THE CITY OF HARTFORD 1.-10. Paragraphs aile through ten of Count One are hereby made paragraphs one though ten of this count. 11. The hereinafter stated injuries and damages to the plaintiff, Willie Edwards were caused by the extreme and outrageous conduct of The City of Hartford, its agents servants or employees in one or more of the following ways: (a) That the Supervisor Stewart Issac's language was so coarse as he knew or should have known that Mr. Edwards would suffer as a result of his conduct. (b) The intervention of the Mayor into a personnel matter 011 behalf of his spouse was designed to strike fear and concem into Mr. Edwards. 12-13 Paragraphs twelve and thirteen of the First Count are hereby made paragraphs twelve and thirteen of this count.

WHEREFORE, the plaintiff claims: 1. Damages; 2. Such other and further relief as law and equity may provide.

THEPL~ards By .

John Kardaras, his attorney 124 Jefferson Street Hartford, Connecticut 06106 Phone #: 860527-9611 Juris #: 402742

RETURN DATE: JUNE 28,2011 WILLIE EDWARDS

:SUPERIOR COURT :J. D. OF HARTFORD :ATHARTFORD MAY 27,2011

vs
THE CITY OF HARTFORD, BT AL

AMOUNT IN DEMAND Plaintiffs claim and demand monetary damages and the amount in demand is greater than FIFTEEN THOUSAND ($15,000.00) DOLLARS, exclusive of interest and costs.

DY~ John Kardaras, his attorney 124 Jefferson Street Hartford, Connecticut 06106 Phone #: 860527-9611 Juris #: 402742