RETURN: OCTOBER 12, 2010

CHRISTINE MAISANO, suing on : SUPERIOR COURT

behalf of her minor child Jane Doe, :
and PATRICIA DePALMA, suing on :
behalf of her minor child Sara Doe :
:
VS. : J. D. OF NEW HAVEN
:
NICHOLAS R. PALLADINO, :
RONALD DeNUZZO, :
ANTHONY R. SERIO and :
DOM MILANO : SEPTEMBER 13, 2010

COMPLAINT

COUNT ONE

1. The plaintiffs are adult citizens of the United States who reside in East

Haven, Connecticut. They bring this action on behalf of their minor children,

herein described as Jane Doe and Sara Doe, to protect their privacy. Jane Doe

and Sara Doe are students in the East Haven Public Schools.

2. The defendants Palladino and DeNuzzo are members of the East

Haven Board of Education. The defendant Serio is the East Haven

Superintendent of Schools. The defendant Milano is a Security Guard at East

Haven High School. All defendants are sued only in their individual capacities.

3. At all times mentioned in this Complaint, the defendants acted jointly

and in concert with each other for the improper and unlawful purposes herein

1
described.

4. In June 2010, motivated solely by political differences with Christine

Maisano and Patricia DePalma, the mothers of the victim plaintiffs herein, the

defendants Palladino and DeNuzzo visited the East Haven High School and

attempted to use their powers as members of the East Haven Board of

Education to coerce members of the faculty and staff of the school to disclose to

them confidential educational records of Jane Doe and Sara Doe. The

defendants Palladino and DeNuzzo intended to use those records to gain

political advantage over the mothers of the students without regard to any injury

they might thereby inflict upon the children.

5. On or about June 25, 2010, the defendants Palladino, DeNuzzo and

Serio, acting illegally and without authorization of the Board of Education,

ordered the expenditure of public funds to hire a third party, one Dan Markle, to

gain access to the confidential educational records of Jane Doe and Sara Doe to

which neither he nor the defendants Palladino and DeNuzzo were entitled.

6. On June 29, 2010, the defendant Serio coerced Gina Fronte, the

Attendance Clerk at East Haven High School, to unlawfully disclose confidential

educational information concerning Jane Doe to the aforesaid Dan Markle.

7. On July 1, 2010, the defendant Serio coerced Barbara Loesche, the

Secretary to the Principal of East Haven High School, to unlawfully disclose

2
confidential educational information concerning Jane Doe to the aforesaid Dan

Markle.

8. On June 29, 2010, the defendant Serio coerced Michele Madonna, a

Guidance Counselor at East Haven High School, to unlawfully disclose

confidential educational information concerning Jane Doe to the aforesaid Dan

Markle.

9. On August 16, 2010, the defendant Serio coerced Joe Marangell, a

teacher at East Haven High School, to unlawfully disclose confidential

educational information concerning Sara Doe to the aforesaid Dan Markle.

10. On July 1, 2010, the defendant Dom Milano unlawfully disclosed

confidential educational information concerning Jane Doe to the aforesaid Dan

Markle.

11. On August 24, 2010, the defendant Serio, acting under the direction

of and in conspiracy with the defendants Palladino and DeNuzzo, unlawfully

disclosed to the defendants Palladino and DeNuzzo, and unlawfully disclosed to

other members of the East Haven Board of Education, including Thomas S.

Hennessey, Laura L. Kluth, Raymond D. Pompano, Charles V. Scalesse and

Kristen L. Vineyard, a written document prepared by the aforesaid Dan Markle

which recited in detail confidential educational information concerning Jane Doe

and Sara Doe which Markle had illegally obtained from educators employed by

3
the East Haven Public Schools. Thereafter, the defendant Palladino maliciously

and unlawfully disclosed the same document to Patricia Cofrancesco and James

Cirillo, neither of whom had any legal right to see the document nor any

legitimate interest therein.

12. As a result, the victim plaintiffs Jane Doe and Sara Doe have suffered

emotional distress.

WHEREFORE the plaintiff Christine Maisano claims judgment against the

defendant Palladino for invasion of privacy.

COUNT TWO

1 - 12. Paragraphs 1 through 12 of Count One are hereby made

Paragraphs 1 through 12 of Count Two.

WHEREFORE the plaintiff Christine Maisano claims judgment against the

defendant DeNuzzo for invasion of privacy.

COUNT THREE

1 - 12. Paragraphs 1 through 12 of Count One are hereby made

Paragraphs 1 through 12 of Count Two.

WHEREFORE the plaintiff Christine Maisano claims judgment against the

defendant Serio for invasion of privacy.

4
COUNT FOUR

1 - 12. Paragraphs 1 through 12 of Count One are hereby made

Paragraphs 1 through 12 of Count Four.

WHEREFORE the plaintiff Christine Maisano claims judgment against the

defendant Milano for invasion of privacy.

COUNT FIVE

1 - 12. Paragraphs 1 through 12 of Count One are hereby made

Paragraphs 1 through 12 of Count Five.

WHEREFORE the plaintiff Patricia DePalma claims judgment against the

defendant Palladino for invasion of privacy.

COUNT SIX

1 - 12. Paragraphs 1 through 12 of Count One are hereby made

Paragraphs 1 through 12 of Count Six.

WHEREFORE the plaintiff Patricia DePalma claims judgment against the

defendant DeNuzzo for invasion of privacy.

COUNT SEVEN

1 - 12. Paragraphs 1 through 12 of Count One are hereby made

5
Paragraphs 1 through 12 of Count Seven.

WHEREFORE the plaintiff Patricia DePalma claims judgment against the

defendant Serio for invasion of privacy.

COUNT EIGHT

1. The plaintiffs are adult citizens of the United States who reside in East

Haven, Connecticut. They bring this action on behalf of their minor children,

herein described as Jane Doe and Sara Doe, to protect their privacy. Jane Doe

and Sara Doe are students in the East Haven Public Schools.

2. The defendants Palladino and DeNuzzo are members of the East

Haven Board of Education. The defendant Serio is the East Haven

Superintendent of Schools. The defendant Milano is a Security Guard at East

Haven High School. All defendants are sued only in their individual capacities.

3. At all times mentioned in this Complaint, the defendants acted jointly

and in concert with each other for the improper and unlawful purposes herein

described.

4. In June 2010, motivated solely by political differences with Christine

Maisano and Patricia DePalma, the mothers of the victim plaintiffs herein, the

defendants Palladino and DeNuzzo visited the East Haven High School and

attempted to use their powers as members of the East Haven Board of

6
Education to coerce members of the faculty and staff of the school to disclose to

them confidential educational records of Jane Doe and Sara Doe. The

defendants Palladino and DeNuzzo intended to use those records to gain

political advantage over the mothers of the students without regard to any injury

they might thereby inflict upon the children.

5. On or about June 25, 2010, the defendants Palladino, DeNuzzo and

Serio, acting illegally and without authorization of the Board of Education,

ordered the expenditure of public funds to hire a third party, one Dan Markle, to

gain access to the confidential educational records of Jane Doe and Sara Doe to

which neither he nor the defendants Palladino and DeNuzzo were entitled.

6. On June 29, 2010, the defendant Serio coerced Gina Fronte, the

Attendance Clerk at East Haven High School, to unlawfully disclose confidential

educational information concerning Jane Doe to the aforesaid Dan Markle.

7. On July 1, 2010, the defendant Serio coerced Barbara Loesche, the

Secretary to the Principal of East Haven High School, to unlawfully disclose

confidential educational information concerning Jane Doe to the aforesaid Dan

Markle.

8. On June 29, 2010, the defendant Serio coerced Michele Madonna, a

Guidance Counselor at East Haven High School, to unlawfully disclose

confidential educational information concerning Jane Doe to the aforesaid Dan

7
Markle.

9. On August 16, 2010, the defendant Serio coerced Joe Marangell, a

teacher at East Haven High School, to unlawfully disclose confidential

educational information concerning Sara Doe to the aforesaid Dan Markle.

10. On July 1, 2010, the defendant Serio coerced the defendant Dom

Milano to unlawfully disclose confidential educational information concerning

Jane Doe to the aforesaid Dan Markle.

11. On August 24, 2010, the defendant Serio, acting under the direction

of and in conspiracy with the defendants Palladino and DeNuzzo, unlawfully

disclosed to the defendants Palladino and DeNuzzo, and unlawfully disclosed to

other members of the East Haven Board of Education, including Thomas S.

Hennessey, Laura L. Kluth, Raymond D. Pompano, Charles V. Scalesse and

Kristen L. Vineyard, a written document prepared by the aforesaid Dan Markle

which recited in detail confidential educational information concerning Jane Doe

and Sara Doe which Markle had illegally obtained from educators employed by

the East Haven Public Schools. Thereafter, the defendant Palladino maliciously

and unlawfully disclosed the same document to Patricia Cofrancesco and James

Cirillo, neither of whom had any legal right to see the document nor any

legitimate interest therein.

12. The conduct of the defendants described above was extreme and

8
outrageous and was carried out in reckless disregard of the probability that it

would cause the minor victim plaintiffs to suffer emotional distress.

13. As a result, the victim plaintiffs Jane Doe and Sara Doe have suffered

severe emotional distress.

WHEREFORE the plaintiff Christine Maisano claims judgment against the

defendant Palladino for intentional infliction of emotional distress.

COUNT NINE

1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made

Paragraphs 1 through 13 of Count Nine.

WHEREFORE the plaintiff Christine Maisano claims judgment against the

defendant DeNuzzo for intentional infliction of emotional distress.

COUNT TEN

1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made

Paragraphs 1 through 13 of Count Ten.

WHEREFORE the plaintiff Christine Maisano claims judgment against the

defendant Serio for intentional infliction of emotional distress.

9
COUNT ELEVEN

1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made

Paragraphs 1 through 13 of Count Eleven.

WHEREFORE the plaintiff Patricia DePalma claims judgment against the

defendant Palladino for intentional infliction of emotional distress.

COUNT TWELVE

1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made

Paragraphs 1 - 13 of Count Twelve.

WHEREFORE the plaintiff Patricia DePalma claims judgment against the

defendant DeNuzzo for intentional infliction of emotional distress.

COUNT THIRTEEN

1 - 13. Paragraphs 1 through 13 of Count Eight are hereby made

Paragraphs 1 - 13 of Count Thirteen.

WHEREFORE the plaintiff Patricia DePalma claims judgment against the

defendant DeNuzzo for intentional infliction of emotional distress.

10
THE PLAINTIFFS

BY_______________________________
JOHN R. WILLIAMS (#67962)
51 Elm Street
New Haven, CT 06510
(203) 562-9931
Fax: (203) 776-9494
jrw@johnrwilliams.com
Their Attorney

11
RETURN: OCTOBER 12, 2010

CHRISTINE MAISANO, suing on : SUPERIOR COURT

behalf of her minor child Jane Doe, :
and PATRICIA DePALMA, suing on :
behalf of her minor child Sara Doe :
:
VS. : J. D. OF NEW HAVEN
:
NICHOLAS R. PALLADINO, :
RONALD DeNUZZO, :
ANTHONY R. SERIO and :
DOM MILANO : SEPTEMBER 13, 2010

PRAYER FOR RELIEF

The plaintiffs claim judgment for compensatory damages and punitive

damages in an amount greater than fifteen thousand dollars ($15,000.00),

exclusive of interest and costs.

THE PLAINTIFFS

BY:________________________________
JOHN R. WILLIAMS (#67962)
51 Elm Street
New Haven, CT 06510
(203) 562-9931
Fax: (203) 776-9494
jrw@johnrwilliams.com
Their Attorney

12