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RETURN DATE: January 18, 2011 : SUPERIOR COURT

DARLENE JONES, : JUDICIAL DISTRICT OF


Plaintiff : MIDDLESEX

v. : AT MIDDLETOWN
:
TOWN OF WESTBROOK, NOEL BISHOP:
PAUL CONNELLY, GEORGE PYTLIK :
and CHRISTOPHER EHLERT,
Defendants : December 15, 2010

COMPLAINT

Count One (Defamation)


1. The plaintiff, DARLENE JONES (“Jones”), is and was at all times relevant to this

matter a resident of the Town of Westbrook, Connecticut.

2. On or about November 2007, Jones was elected to a two year term as Town

Treasurer for the Town of Westbrook.

3. In November 2009 Jones was re-elected by the citizens of Westbrook for an

additional two year term as Town Treasurer.

4. The defendant, TOWN OF WESTBROOK (“Town”), is and was at all times

relevant to this matter, a municipal corporation under the laws of the State of Connecticut.

LICARI , WALSH
& SKLAVER, LLC
105 COURT STREET
NEW HAVEN, CT 06511
------------
(203) 752-1450
FAX (203) 752-1401
-------------

JURIS NO. 417195


5. The defendant, NOEL BISHOP, (“Bishop”) is and was at all times relevant to this

matter the First Selectman for the Town of Westbrook. He is being sued in both his official

and his personal capacity.

6. The defendant, PAUL CONNELLY, (“Connelly”) is and was at all times relevant to

this matter the Chairman of the Board of Finance for the Town of Westbrook. He is being

sued in both his official and his personal capacity.

7. The defendant, GEORGE PYTLIK, (“Pytlik”) is and was at all times relevant to this

matter a member of the Town of Westbrook Board of Finance. He is being sued in both his

official and his personal capacity.

8. The defendant, CHRISTOPHER EHLERT, (“Ehlert”) is and was at all times

relevant to this matter a member of the Board of Finance for the Town of Westbrook. He is

being sued in both his official and his personal capacity.

9. Since her election as Town Treasurer, the Defendants have engaged in a systematic

pattern of conduct, both individually and collectively, with the intent of damaging

plaintiff’s reputation and rendering her ineffective as Town Treasurer.

10. The Defendants have refused plaintiff’s requests for increased hours and additional

staff, while at the same time decreasing plaintiff’s Department Budget and reducing her

staff.
LICARI , WALSH
& SKLAVER, LLC
105 COURT STREET
NEW HAVEN, CT 06511
------------
(203) 752-1450
FAX (203) 752-1401
-------------

JURIS NO. 417195

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11. In addition, defendants have repeatedly made false and defamatory statements about

plaintiff and her performance as Town Treasurer.

12. The defamatory statements have identified plaintiff to third parties and have been

published to those third parties at public meetings of both the Town of Westbrook Board of

Selectmen as well as the Town of Westbrook Board of Finance.

13. The statements made by the defendants were false and/or made with reckless

disregard for the truth.

14. As a result of the defamatory statements Jones’ reputation in municipal finance as

well as private finance has been significantly damaged such that Jones has been unable to

secure full or part time employment within her chosen field of accounting.

Count Two (Intentional Infliction of Emotional Distress)

1-14. Paragraphs one through fourteen of count one are hereby incorporated by reference and

are made paragraphs one through fourteen of count two.

15. The plaintiff has suffered severe mental and emotional distress due to the defendant’s

actions as well as humiliation, indignity and harm to her reputation as a result of these

actions.

16. The defendant’s actions were extreme and outrageous.

LICARI , WALSH
& SKLAVER, LLC
105 COURT STREET
NEW HAVEN, CT 06511
------------
(203) 752-1450
FAX (203) 752-1401
-------------

JURIS NO. 417195

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17. The defendant’s knew or should have known that their actions would cause severe

injury to the plaintiff.

Count Three (Negligent Infliction of Emotional Distress)

1-14 Paragraphs one through fourteen of count one are hereby incorporated by reference and

are made paragraphs one through fourteen of count three.

15. The defendants knew or should have reasonably foreseen that their conduct as well as

that of their agents involved an unreasonable risk of causing emotional distress and that

the distress, if it were caused, might result in illness or bodily harm.

Wherefore, the Plaintiff Claims:

ON THE FIRST COUNT


1. Compensatory damages.
2. Such other and further relief to which the plaintiff is, at law, or in equity and by
statute entitled.

ON THE SECOND COUNT


1. Compensatory damages.
2. Such other and further relief to which the plaintiff is, at law, or in equity and by
statute entitled.

ON THE THIRD COUNT


1. Compensatory Damages.
LICARI , WALSH
& SKLAVER, LLC
105 COURT STREET
NEW HAVEN, CT 06511
------------
(203) 752-1450
FAX (203) 752-1401
-------------

JURIS NO. 417195

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2. Such other and further relief to which the plaintiff is, at law, or in equity and by
statute entitled.

THE PLAINTIFF

BY: ______________________________
John M. Walsh Jr., Esq.
LICARI, WALSH & SKLAVER, LLC
His Attorney

The plaintiff claims compensatory damages in an amount in excess of FIFTEEN

THOUSAND and 00/100 DOLLARS ($15,000.00), exclusive of interest and costs.

____________________________
John M. Walsh, Jr., Esq.

LICARI , WALSH
& SKLAVER, LLC
105 COURT STREET
NEW HAVEN, CT 06511
------------
(203) 752-1450
FAX (203) 752-1401
-------------

JURIS NO. 417195