UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

Anthony McKnight Sr. Plaintiff, v. State of Connecticut ET. AL., Defendants.

DATE: April 19, 2012

FILE NO: 3:10cv1471(MRK)

Amended Complaint 1.) The Defendant, State of Connecticut public officials, were negligent in their fiduciary obligations created through plaintiffs entitlements to 5-142(a) benefits {As enacted 1993}. The defendants unlawfully terminated Plaintiffs employment. 2.) The Malfeasance on behalf of the Defendant State of Connecticut was the proximate cause of Plaintiffs loss of property and other liberties and rights guaranteed Plaintiff pursuant to the Constitution of the United States and its Statutes and the laws of the State of Connecticut. 3.) The Defendant State of Connecticut violated the Plaintiffs civil and statutory rights when public officials terminated the Plaintiff while the Plaintiff was out of work due to inmate related, hazardous duty, work compensable injuries. Background 1.) The Plaintiff, an African American, was hired by the Defendant State of Connecticut in a Hazardous Duty capacity on April 3, 1987{See First Amended Complaint}. 2.) The Plaintiff suffered career ending disabilities on April 26, 1993 where it was determined by Defendant, and Plaintiff physicians that the Plaintiff was, in fact, no

longer able to perform the duties of a corrections officer due to the injuries suffered during an altercation with dangerous inmates while in the employ of the Defendant State of Connecticut. Department of Corrections {See Appendix, Miles}. 3.) Unlike similarly situated injured Caucasian corrections officers, the Plaintiff was unlawfully terminated by the Defendant State of Connecticut, while absent from work due to his inmate related, work compensable injuries {See termination doc letters etc.}. 4.) The Plaintiff contends that the Defendant State of Connecticut/SEBAC Agreements(IV,V,2011) violated Plaintiffs rights as it fosters and promotes discrimination through fraud and artificial reductions of African American corrections officers Disability Compensation Entitlements through the its unfunded policies carried out by its agencies. 5.) The Connecticut Legislature on March 6, has approved the ambiguity and fraudulent language in Attachments D and H the Agreement in favor of the Defendant public officials which violates African American corrections officers Civil Rights to Equal Protections of the Law as it relates to those benefits received by white corrections officers similarly situated.. Damages 1.) As Damages the Plaintiff requests equitable benefits to those issued to similarly situated injured Caucasian Corrections Officers qualifying for 5-142(a) benefits. 2.) The Plaintiff requests $500,000.00. In damages to replace the house constructively seized by the Defendant State of Connecticut through its Department of Revenue Services, Economic And Community Development, Department of Corrections

etc. 3.) The Plaintiff requests medical benefits and salary and deductions consistent with those established for similarly situated injured Caucasian corrections officers eligible for such. 4.) The Plaintiff requests salary and payroll deductions as in the case of similarly situated injured Caucasian corrections employees qualifying for 5-142(a) benefits. 5.) The process of Plaintiffs Hazardous Duty Retirement Application submitted to the Office of the Comptroller, State of Connecticut, August 2009, as in the case of similarly situated injured Caucasian corrections officers, such as Michael Cozzolino acknowledged by Commissioner Delaney of the Defendant Workers Compensation Commission.

Respectfully Submitted, By:_______________________________ Anthony McKnight Sr., M.P.A, M.S. P.O Box 304 West Haven CT 06516 Email: Anthonymcknightsr@gmail.com Telephone: 203-675-7722

CERTIFICATION This is to certify that a copy of the foregoing has been mailed via U.S. Mail to the Defendant, Asst. Attorney General Maura Murphy-Osborne, State of Connecticut, Office of the Attorney General, 55 Elm Street, Hartford and to maura.murphyosborne@ct.gov, This ____Day of April, 2012.