summons - CIVIL Rev. 4.15 STATE OF CONNECTICUT 0.13.3. 51-345. 51-347. 51-349. 51-350. 5245a. SUPERIOR COURT ??3-1throug 3-2 3-1 10- See other side for instructions Ci ifamount. legal interest or property in demand. not including interest and costs is less than $2.500. Ci if amount, legal interest or property in demand. not including interest and costs is $2.500 or more. El if claiming other relief in addition to or in lieu of money or damages. TO: Any proper officer; BY AUTHORITY OF THE STATE OF CONNECTICUT. you are hereby commanded to make due and legal service of this Summons and attached Complaint. Address of court clerk where writ and other papers shall be tiled (Number. street. town and zip code} Telephone number of clerk Return Date {Must be a Tuesday) (0.6.8. 51-346. 51-350) (with area code) 1061 Main Street. Bridgeport. CT 06604 (203 )579-5527 g_l% Judicia' District GA. At (T own in which writ ls returnable) (C. G. S. 51-346. 51-3349) Case type code (See list on page 2) Housing Session Number: Bridgeport Major: 7 Minor: 90 For the Plaintif?s) please enter the appearance of: Name and address of attorney. law firm or plaintiff it self-represented (Number: street. town and zip code} Jurls number (to be entered by aiiomey only) Antonio Ponvert ill, Koskoff Koskoff 8: Bieder. 350 Fairfield Avenue, Bridgeport, CT 05504 032250 Telephone number ("with area code) Signature of Plaintiff (itself-represented) 203 336-4421 The attorney or law firm appearing for the pialntili'. or the main?, If Email address for delivery of papers under Section 10-13 (if agreed to} self-represented. agrees to accept papers (service) electronically In El Yes El No aponvert@koskoff.corn this case under Section 10-13 of the Connecticut Practice Book. Number of Plaintiffs: 1 Number of Defendants: 16 IE Form JD-CV-Z attached for additional parties Parties Name (Last, First. Middle initial) and Address of Each party (Number; Street; P.O. Box; Town; State; Zip; Country, ?not USA) First Name: Shehadi. William H. Jr., a conserved person, by through the conservator of his Est, Albert B. Shehadi Plaintiff 27 Byram Shore Road. Greenwich, CT 06830 Additional Name: P-02 Plaintiff Address: First Name: The State of Connecticut Dehndam clo Office of the Attorney General. 55 Elm Street, Hartford. CT 06106 Additional Name: The Connecticut Department of Mental Health and Addiction Services 0-02 Defendant Mm? 410 Capitol Avenue, Hartford. CT 05134 Additional Name: The Whiting Forensic Division of Connecticut Valley Hospital 0413 Defendant ?at? PO Box 70, Middletown. CT 06457 Additional Name: Whiting Forensic Hospital 0-04 Defendant Wm? PO Box 70. Middletown, CT 06457 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 noti?ed of further proceedings, you or your attorney must ?le 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. You 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 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 on-Iine at ww.jud.ct.gov 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 legal questions. I, 8810 Signed {Sign and x) 8:32.111; c413; a Name 0 Person Signing at Left Date signed cm Antonio Ponvert Ill Bil/18 If this Summons is signed by a Clerk: For Court Use Only a. The signing has been done so that the Plaintif?s) will not be denied access to the courts. File Date b. It is the responsibility of the Plaintif?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. The Clerk signing this Summons at the request of the Plaintif?s) is not responsible in any way for any errors or omissions in the Summon? any allegations contained in the Complaint. or the service of the Summons or Complaint. I certify have read and Signed Pleintf?) Date Docket Number understand the above: 12 SUMMONS - CIVIL .113.ch Rev. 4.13 STATE OF CONNECTICUT essay-345. 51-347. 51-349. 51-350. 5245a. SUPERIOR COURT 52-48. 259. PB. 3-1 through 3-21. 6-1. 10-13 .111 d. of. gov See other side for instructions if amount. legal interest or property in demand. not including interest and costs is less than $2.500. El if amount, legal interest or property in demand. not including interest and costs is $2.500 or more. if claiming other relief in addition to or in lieu of money or damages. TO: Any proper of?cer. BY AUTHORITY OF THE STATE OF CONNECTICUT. you are hereby commanded to make due and legal service of this Summons and attached Complaint. Address of court clerk where writ and other papers shall be filed (Number. street. town and zip code) Telephone number of clerk Return Date (Must be a Tuesday) 51-346. 51-350) faith area code} A r" 17 018 1061 Main Street. Bridgeport. CT 06604 (203 )579-6527 LET. Judicial District I: GA. At {Town in which writ is returnable} 55 51-346. 51-349) Case type code {See list on page 2} Housing Session Number. Bridgeport Major. Minor: 90 For the Plaintif?s) please enter the appearance of: Name and address of attorney. law firm or plaintiff if sell-represented {Numben street. town and zip code) Jurls number (to be entered by attorney only} Antonio Ponvert Ill. Koskoff Koskoff Bieder. 350 Fairfield Avenue. Bridgeport. CT 06504 032250 Telephone number (with area code} Signature of Plaintiff (ifsei?represented) 203 336-4421 The attorney or law ?rm appearing for the plaintiff. or the plaintiit it Email address for delivery of papers under Section 10-13 (if agreed to) sail-represented. agrees to accept papers (service) electronically in Yes No aponvert@koskoff.com this case under Section 10-13 of the Connecticut Practice Book. Number of Plaintiffs: 1 Number of Defendants: 16 Form JD-CV-2 attached for additional parties Parties Name (Last. First. Middfe initial) and Address of Each party (Number; Street; P. O. Box; Town; State; Zip; Country. if not USA) First Name: Shehadi. William H. Jr.. a conserved person. by 81 through the conservator of his Est.. Albert B. Shehadi P-01 Plal?t?? Mm": 27 Byram Shore Road. Greenwich. CT 06830 Additional Name: P412 Plaintiff First Name: The State of Connecticut D-01 ?af?n?ia?t Add"?? cio Office of the Attorney General. 55 Elm Street. Hartford. CT 05106 Additional Name: The Connecticut Department of Mental Health and Addiction Services 0-02 Defendant 410 Capitol Avenue, Hartford. CT 06134 Additional Name: The Whiting Forensic Division of Connecticut Valley Hospital 0-03 Defendant ?drew PO Box 70. Middletown. CT 06457 Additional Name: Whiting Forensic Hospital 0-04 Defendant ?We PO Box 70. Middletown. or 06457 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 noti?ed of further proceedings. you or your attorney must ?le 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. You 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 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 on-line at m.jud.cf.gov 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 legal questions. I Signed (Sign and er of the Name of Person Signing at Left Date signed 1? Assistant Clerk Antonio Ponvert If this Summons is signed by a Clerk: For Court Use Only a. The signing has been done so that the Plaintiff(s) will not be denied access to the courts. File Date 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. The Clerk signing this Summons at the request of the Plainti?ts) is not responsible in any way for any en'ors or omissions in the SummohE any allegations contained in the Complaint. or the service of the Summons or Complaint. certify have read and Signed (Self-Represanted Date Docket Number understand the above: (Page 1 of 2) CIVIL SUMMONS STATE OF CONNECTICUT CONTINUA ION OF TIEs Jo.cv.2 Rm. 112 AR SUPERIOR COURT First named Plaintiff (Last, First, Middle initial) Shehadi, William H. Jr. First named Defendant (Last, First, Middle initial} The State of Connecticut Additional Plaintiffs Name (Last, First, Middle initial, if individual) Address (Number: Street, Town and Zip Code) CODE Additional Defendants Name (Last, First, Middle initial, Address (Number, Street, Town and Zip Code} CODE Delphin-Rittmon, Miriam E., DMHAS Commissioner 05 410 Capitol Avenue, Hartford, CT 06134 Vartelas, Helen, Connecticut Valley Hospital Chief Executive Of?cer 06 1000 Silver Street, Middletown, CT 06457 Ward-McKinley, Thomas 07 693 Cahill Court, Cheshire, CT 06410 Kozak, Renata 08 70 Zenith Lane, Glastonbury, CT 06033 Birkbeck, Helen 09 321 Fourth Street, Long Beach, MS 39560 Uyanwune-Clark, Miriam 10 10 Rhodora Terrace, Windsor, CT 06095 Candelaria, Licella 11 143 Catherine Drive, Meriden, CT 06450 Stout, Yvette FOR COURT USE ONLY- File Date 5 David Circle. Windsor, CT 06095 12 Bartinicki. Brenda 20 Blueberry Lane, Jewett City, CT 06351 13 Guitard, Paul 33 Round Hill Road, Middletown, CT 06457 14 Docket number CIVIL SUMMONS-Continuation CIVIL SUMMONS STATE OF CONNECTICUT CONTINUAT OF PAR mm 9.19 "Es SUPERIOR COURT "?rst named PIaInu? fuel. ?rst. Middle Inmau Shehadi, William H. Jr. First named Defendant (Last. First. Middle lumen! The State of Connecticut Additional Plaintiffs Name {Last First. Mldt?e initial. ifmdividual} Address {Numbers Street. Tom and Zip Code) CODE Additional Defendants Name (Last, First, Middle initial, ifindividua? Address (Numben Street, Town and Zip Code) ICODE Vallejo. John 115 71 Scott Road, Prospect. CT 06712 Tilley. Gregg 16 50 Brightwood Lane, West Hartford. CT 06110 07 OB 09 10 1 1 FOR COURT USE ONLY - File Date 12 13 14 Docket number CIVIL RETURN DATE: 4/17/18 WILLIAM H. SHEHADI, JR., A CONSERVED PERSON, BY AND THROUGH THE CONSERVATOR OF HIS ESTATE, ALBERT B. SHEHADI V. THE STATE OF CONNECTICUT, THE CONNECTICUT DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES, THE WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL, WHITING FORENSIC HOSPITAL, DMHAS COMMISSIONER MIRIAM E. PH.D., CONNECTICUT VALLEY HOSPITAL CHIEF EXECUTIVE OFFICER HELEN WHITING ACTING DIRECTOR THOMAS WARD-MCKINLAY, WHITING CHIEF OF PATIENT CARE SERVICES RENATA KOZAK, 2N0 SHIFT DIRECTOR OF NURSING HELEN BIRKBECK, 3RD SHIFT DIRECTOR OF NURSING MIRIAM UYANWUNE-CLARK, 1ST SHIFT NURSE SUPERVISOR LICELIA CANDELARIA, 1ST SHIFT NURSE SUPERVISOR YVETTE STOUT, 2ND SHIFT NURSE SUPERVISOR BRENDA BARTNICKI, 2ND SHIFT NURSE SUPERVISOR PAUL GUITARD, 3RD SHIFT NURSE SUPERVISOR JOHN VALLEJO, AND 3HD SHIFT NURSE SUPERVISOR GREGG TILLEY COMPLAINT INTRODUCTION SUPERIOR COURT JUDICIAL DISTRICT OF FAIRFIELD AT BRIDGEPORT MARCH 1, 2018 1. When the State takes a person into its custody and holds him there against his will, the United States Constitution and Connecticut law impose upon it a corresponding duty to assume responsibility for the person?s safety and well-being. 2. The rationale for this principle is simple enough: when the State by the affirmative exercise of its power so restrains an individual's liberty that it renders him unable to care for himself, and at the same time fails to provide for his basic human needs - adequate care and supervision, humane and dignified treatment, reasonable protection from harm, and freedom from torture and abuse inflicted by the State?s own agents and employees it transgresses the substantive limits on state action set by the Due Process Clause of the Fourteenth Amendment, violates the person?s Constitutionally protected liberty interests, and deprives the individual of his rights under state statutory and common law. 3. In the context of government operated hospitals, among the State's first obligations is to ensure the safety of the vulnerable, mentally ill human beings committed to the State?s care and custody. 4. The State of Connecticut, the state agency and hospitals charged with the care and supervision of institutionalized mentally ill persons, and the state officials, agents and employees responsible for the well-being of mentally ill persons in state custody deliberately violated these well-established principles of Constitutional law and these basic tenets of an even minimally civilized people. 5. As a result of the State's and its agents' deliberate and intentional violation of the law, the plaintiff William H. Shehadi, Jr., a profoundly mentally ill and vulnerable institutionalized person, was subjected to daily mistreatment, degradation, physical assaults, ridicule, and other forms of brutal and inhuman emotional and physical torture inflicted over a period of years by the nurses and specialists responsible for his care. 6. This Complaint seeks monetary damages and injunctive relief pursuant to the Due Process Clause of the Fourteenth Amendment to the United States Constitution, 42 U.S.C. 1983 and 1988, the Connecticut Patients? Bill of Rights, Conn. Gen. Stats. 17a-540, etseq., and Connecticut common law. PARTIES 7. WILLIAM (BILL) H. SHEHADI, JR., is a citizen of the United States and the State of Connecticut. In 1995, the Connecticut Superior Court acquitted MR. SHEHADI of criminal charges due to his severe mental illness, and committed him to the jurisdiction of the Security Review Board of defendant DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES (DMHAS), pursuant to Conn. Gen. Stat. His last permanent residence was in Greenwich, Connecticut, but he has been involuntarily confined since his acquittal in maximum security hospitals operated, controlled and supervised by defendants STATE OF CONNECTICUT and DMHAS. 8. Plaintiff ALBERT B. SHEHADI is BILL brother and the conservator of estate and oo-conservator of his person. The Probate Court Appointment of Conservator is attached hereto. ALBERT SHEHADI is a citizen of the United States and the State of Connecticut, and resides in Greenwich, CT. 9. KAREN KANGAS is the co-conservator of BILL's person, and has been his friend and advocate for more than 30 years. She supports and agrees with the filing of this Complaint, and with all requests for monetary and injunctive relief that will ensure safe, appropriate, least restrictive, and maximally therapeutic conditions of treatment and confinement for BILL for as long as it is medically and required. 10. During the period of BILL confinement and abuse, defendant STATE OF CONNECTICUT, a governmental entity, funded and operated, and continues to fund and operate, THE DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES (DMHAS), a state agency. The STATE is sued for injunctive relief and compensatory monetary damages for violations of the Connecticut Patients? Bill of Rights. 11. Defendant DMHAS operated, controlled and supervised, and continues to operate, control and supervise, the maximum security hospitals where BILL SHEHADI has been and is confined, variously known as THE WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL and THE WHITING FORENSIC HOSPITAL. DMHAS is sued for injunctive relief and compensatory monetary damages for violations of the Patients? Bill of Rights. 12. On December 29, 2017, Connecticut Gov. Dannel P. Malloy signed Executive Order 63, separating defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL from Connecticut Valley Hospital, placing it within the Whiting Forensic Division of DMHAS, and re-naming it WHITING FORENSIC HOSPITAL. The Order was to be effective December 31, 2017. Defendants WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL and WHITING FORENSIC HOSPITAL are, where not otherwise specified, hereafter referred to as WHITING. They are sued for injunctive relief and compensatory monetary damages for violations of the Patients? Bill of Rights. 13. During the period of BILL confinement from the time of his acquittal until December 31, 2017, defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL was a maximum and enhanced security facility within the DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES confining, among others, persons committed to the Security Review Board pursuant to Conn. Gen. Stat. It had a capacity of 106 maximum security beds, 12 of which were on Unit 6, where BILL SHEHADI was confined during the period of abuse, and 141 enhanced security beds. 14. During the period of BILL confinement after December 31, 2017, to the present time, defendant WHITING FORENSIC HOSPITAL was and is a maximum and enhanced security facility within the DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES confining, among others, persons committed to the Security Review Board pursuant to Conn. Gen. Stat. 15. Defendant MIRIAM is, and was at all relevant times, the Commissioner of DMHAS. As such, she was responsible for: the administration of all DMHAS facilities, including Connecticut Valley Hospital and the care, custody and treatment of persons confined at such facilities, including BILL the hiring, supervision, training, discipline and control of the CEO. of Connecticut Valley Hospital and persons working at WHITING, including the Acting Director, the Chief of Patient Care Services, the Directors of Nursing, the Nurse Supervisors, and the Forensic Nurses and Forensic Treatment Specialists and other WHITING employees named herein; and all of the other duties and obligations set forth in Conn. Gen. Stat. 17a-451. Defendant DELPHIN-RITTMON is sued for compensatory and punitive damages in her individual capacity for violations of the United States Constitution, the Patients' Bill of Rights, and State common law. She is sued for injunctive relief in her official capacity for violations of the United States Constitution. 16. Defendant HELEN VARTELAS is, and was at all relevant times, the Chief Executive Officer of Connecticut Valley Hospital. As such, she was responsible for: the administration of Connecticut Valley Hospital facilities and divisions, including care, custody and treatment of persons confined at WHITING, including BILL assurance of patients' rights; investigation of critical incidents; and hiring, supervision, training, discipline and control of persons working at WHITING, including the Acting Director, the Chief of Patient Care Services, the Directors of Nursing, the Nurse Supervisors, and the Forensic Nurses and Forensic Treatment Specialists named herein. Defendant is sued for compensatory and punitive damages in her individual capacity for violations of the United States Constitution, the Patients' Bill of Flights, and State common law. She is sued for injunctive relief in her official capacity for violations of the United States Constitution. 17. Defendant THOMAS WARD-MCKINLAY is, and was at all relevant times, the Acting Director of defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, he was responsible for: the administration of care, custody and treatment of persons confined at WHITING, including BILL assurance of patients? rights; investigation of critical incidents; and hiring, supervision, training, discipline and control of persons working at WHITING, including the Chief of Patient Care Services, the Directors of Nursing, the Nurse Supervisors, and the Forensic Nurses and Forensic Treatment Specialists named herein. Defendant WARD- MCKINLAY is sued for compensatory and punitive damages in his individual capacity for violations of the United States Constitution, the Patients? Bill of Rights, and State common law. 18. Defendant RENATA KOZAK is, and was at all relevant times, Chief of Patient Care Services at defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, she was responsible for: care, custody and treatment of persons confined at WHITING, including BILL supervision, training, discipline and control of persons working at WHITING, including the Directors of Nursing, the Nurse Supervisors, and the Forensic Nurses and Forensic Treatment Specialists named herein; making rounds to determine quality of nursing care; assuring that optimal quality of care was provided in a safe environment; development and implementation of effective ongoing programs to measure, assess and improve quality of nursing care, treatment and services delivered to patients; intervention in crisis situations and investigation of all unusual incidents; and protection of the human and civil rights of patients. Defendant KOZAK is sued for compensatory and punitive damages in her individual capacity for violations of the United States Constitution, the Patients' Bill of Rights, and State common law. 19. Defendant HELEN BIRKBECK is, and was at all relevant times, the 2nd shift Director of Nursing at defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, she was responsible for: care, custody and treatment of persons confined at WHITING, including BILL assurance of patients' rights; supervision, training, discipline and control of persons working at WHITING including the Nurse Supervisors and the Forensic Nurses and Forensic Treatment Specialists named herein; making rounds to determine quality of nursing care; assuring that optimal quality of care was provided in a safe environment; development and implementation of effective ongoing programs to measure, assess and improve quality of nursing care, treatment and services delivered to patients; intervention in crisis situations and investigation of all unusual incidents; and protection of the human and civil rights of patients. Defendant BIRKBECK is sued for compensatory and punitive damages in her individual capacity for violations of the United States Constitution, the Patients? Bill of Rights, and State common law. 20. Defendant MIRIAM UYANWUNE-CLARK is, and was at all relevant times, the 3rd shift Director of Nursing at defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, she was responsible for: care, custody and treatment of persons confined at WHITING, including BILL assurance of patients' rights; supervision, training, discipline and control of persons working at WHITING, including the Nurse Supervisors and the Forensic Nurses and Forensic Treatment Specialists named herein; making rounds to determine quality of nursing care; assuring that optimal quality of care was provided in a safe environment; development and implementation of effective ongoing programs to measure, assess and improve quality of nursing care, treatment and services delivered to patients; intervention in crisis situations and investigation of all unusual incidents; and protection of the human and civil rights of patients. Defendant UYANWUNE-CLARK is sued for compensatory and punitive damages in her individual capacity for violations of the United States Constitution, the Patients' Bill of Rights, and State common law. 21. Defendant LICELIA CANDELARIA is, and was at all relevant times, one of two 15' shift Nurse Supervisors at defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, she was responsible for: care, custody and treatment of persons confined at WHITING, including BILL assurance of patients? rights; and supervision, training, discipline and control of the Forensic Nurses and Forensic Treatment Specialists named herein. Defendant CANDELARIA is sued for compensatory and punitive damages in her individual capacity for violations of the United States Constitution, the Patients' Bill of Rights, and State common law. 22. Defendant YVETTE STOUT is, and was at all relevant times, one of two 1St shift Nurse Supervisors at defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, she was responsible for: care, custody and treatment of persons confined at WHITING, including BILL assurance of patients? rights; and supervision, training, discipline and control of the Forensic Nurses and Forensic Treatment Specialists named herein. Defendant STOUT is sued for compensatory and punitive damages in her individual capacity for violations of the United States Constitution, the Patients? Bill of Rights, and State common law. 23. Defendant BRENDA BARTNICKI is, and was at all relevant times, one of two 2"d shift Nurse Supervisors at defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, she was responsible for: care, custody and treatment of persons confined at WHITING, including BILL assurance of patients' rights; and supervision, training, discipline and control of the Forensic Nurses and Forensic Treatment Specialists named herein. Defendant BARTNICKI is sued for compensatory and punitive damages in her individual capacity for violations of the United States Constitution, the Patients? Bill of Rights, and State common law. 24. Defendant PAUL GUITARD is, and was at all relevant times, one of two 2"Cl shift Nurse Supervisors at defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, he was responsible for: care, custody and treatment of persons confined at WHITING, including BILL assurance of patients' rights; and supervision, training, discipline and control of the Forensic Nurses and Forensic Treatment Specialists named herein. Defendant GUITARD is sued for compensatory and punitive damages in his individual capacity for violations of the United States Constitution, the Patients? Bill of Rights, and State common law. 25. Defendant JOHN VALLEJO is, and was at all relevant times, one of two 3"d shift Nurse Supervisors at defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, he was responsible for: care, custody and treatment of persons confined at WHITING, including BILL assurance of patients' rights; and supervision, training, discipline and control of the Forensic Nurses and Forensic Treatment Specialists named herein. Defendant VALLEJO is sued for compensatory and punitive damages in his individual capacity for violations of the United States Constitution, the Patients' Bill of Rights, and State common law. 26. Defendant GREGG TILLEY is, and was at all relevant times, one of two 3'd shift Nurse Supervisors at defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. As such, he was responsible for: care, custody and treatment of persons confined at WHITING, including BILL assurance of patients? rights; and supervision, training, discipline and control of the Forensic Nurses and Forensic Treatment Specialists named herein. Defendant TILLEY is sued for compensatory and punitive damages in his individual capacity for violations of the United States Constitution, the Patients? Bill of Flights, and State common law. COUNT ONE (Violation of the Fourteenth Amendment's Guarantee of Reasonable Care and Safe Conditions of Confinement, against defendants Delphin-Ftittmon and Vartelas in their official capacities for injunctive relief, and against defendants Delphin-Ftittmon, Vartelas, Ward-McKinIay, Kozak, Birkbeck, Uyanwune-Clark, Candelaria, Stout, Bartnicki, Guitard, Vallejo, and Tilley in their individual capacities for compensatory and punitive damages, pursuant to 42 U.S.C. 1983): 27. Paragraphs 1-26 are realleged here and fully incorporated into Count One. 28. BILL SHEHADI was born on August 22, 1958, and since early childhood has had a long history of treatment and hospitalizations for illnesses and behavioral problems. 29. In 1995, BILL was committed to the custody of defendant DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES and admitted as a patient to defendant WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL. 30. BILL has been involuntarily institutionalized at WHITING since that time. 31. At all times mentioned herein, BILL suffered from and continues to suffer from severe and persistent mental illness. 32. At all times mentioned herein, BILL suffered from and displayed, and continues to suffer from and display, chronic and acute associated with his mental illness, including: paranoid and delusional thinking, self-injurious behavior, chronic anxiety, profound insomnia which even when treated with sedatives results in him averaging only about four hours of sleep per night; various repetitive 11 behaviors including pacing and tapping, scratching and rubbing his head and body; emotional instability; loose, disorganized, and irrational thought processes; and statements and behaviors responding to internal stimuli of a origin. 33. All WHITING staff responsible for supervision and care, including the defendants and the Forensic Nurses and Forensic Treatment Specialists named herein, knew that BILL suffered extreme agitation and distress when anyone touched him without permission, stared at him, pulled the sheets off his bed, poured liquid on him, approached him from behind, interrupted him, or verbally or physically taunted or approached him in a threatening way. 34. At all times mentioned herein, speech is and has been chronically difficult to understand due to significant dysarthria, a speech disorder caused by muscle weakness. 35. At all times mentioned herein, insight is and has been poor, as he does not know or understand that he suffers from mental illnesses requiring treatment. 36. At all times mentioned herein, BILL suffered from and continues to suffer from severe and permanent medical illnesses and complications, including: Fiecurrent Aspiration Pneumonia; Esophageal Strictures; Chronic, Severe Gastroesophageal Reflux Disorder; Severe Osteoporosis; Hypothyroidism; Anemia; Chronic Renal Insufficiency; Incontinence; Chronic Pancreatitis, Deep Vein Thrombosis; and Seizures. 37. At all times mentioned herein, BILL has required and continues to require assistance from his caregivers with many activities of daily living, including eating and drinking, showering, shaving, dressing, and cleaning his laundry and linens. 12 38. At all times mentioned herein, BILL has had great difficulty relating to others, including caregivers and those trying to assist him, and he has often been incapable of accepting interventions provided to assist him. 39. Simply put, BILL SHEHADI is an extremely ill and vulnerable man who for his entire life has suffered greatly from his afflictions, and who requires help with the most basic tasks of human survival. 40. Notwithstanding his illnesses and the profound challenges caused by them, however, during various times mentioned herein, BILL has participated in the ?Lunch Club? on his WHITING Unit where he ordered food from a local restaurant, has experienced good moods, can be talkative with staff, occasionally sings and watches television in his room or in the Unit common areas, and takes walks in the hospital courtyard. 41. For years, and continuing to the present time, treatment plan has required 24/7 supervision by two WHITING staff members to ensure his safety and wellbeing. 42. For years, and continuing to the present time, room has been continuously monitored by a stationary video camera sending live images to the nurses at the WHITING Unit 6 Nurse?s Station. The video monitoring was required to ensure safety and wellbeing. 43. During the period February 27 to March 22, 2017, WHITING Forensic Nurses and Forensic Treatment Specialists responsible for providing the required 24/7 supervision inflicted on BILL unrelenting sadistic physical abuse, neglect, exploitation, humiliation and torture. 13 44. One or more WHITING Forensic Nurses, Forensic Treatment Specialists, and other WHITING employees were present during every one of the incidents, but, without exception, they failed and refused to stop or report the abuse, and/or the reports, if any, were ignored by the defendants. 45. At the time of the abuse, BILL was 58 years old. 46. If they had been doing their jobs, the WHITING Forensic Nurses were responsible for providing professional nursing evaluation, diagnosis and treatment of mentally ill persons at WHITING. Their duties included: direct patient care, observing and recording the patients? status and actions taken, conferring with WHITING nurses, physicians and supervisors regarding the patients? condition, assessing the patients? needs, teaching the patients skills of self-care, and protecting the patients? human and civil rights. 47. As a condition of their employment, the WHITING Forensic Nurses were required to possess the following knowledge, skills and abilities, among others: knowledge and ability to apply professional nursing practice and ethics, quality standards, and clinical therapeutic models of care; considerable interpersonal skills; ability to act as a role model to health care staff by demonstrating and teaching professional behaviors; ability to listen and provide empathetic assistance to patients; and ability to develop therapeutic relationships with patients. 48. If they had been doing their jobs, the WHITING Forensic Treatment Specialists were responsible for developing and maintaining an effective therapeutic environment for patients. Their duties included: developing and maintaining therapeutic 14 relationships with patients; performing patient care duties such as feeding, bathing and dressing; observing, reporting and recording patient behaviors and appearance; consistently and actively supporting patients? rights; and monitoring and participating in patient management on the units. 49. As a condition of their employment, the WHITING Forensic Treatment Specialists were required to possess the following knowledge, skills, abilities and character requirements, among others: knowledge of human behavior, behavioral manifestations of mental illness and principles involved in the care and treatment of the mentally ill; considerable interpersonal skills; and good character. 50. Fiather than comply with these duties and requirements of their State employment, and in direct violation of them, the Forensic Nurses and Forensic Treatment Specialists responsible for BILL care and treatment inflicted and perpetrated, and were allowed and encouraged by the defendants to inflict and perpetrate, the following brutal and barbaric acts of physical and abuse, neglect and exploitation, all of which are captured on videotape: A. At various times on or about February 27, 2017: 1. two WHITING Forensic Treatment Specialists threw clothing and a cup at BILL while Forensic Nurse Michael Presnick watched from the doorway; 2. Forensic Treatment Specialist (FTS) Robert Martineau put his feet on BILL's bed; 3. FTS Willie Bethea sat on bed and taunted and tormented him by tapping, poking and hitting him approximately 34 times - the 13th and {34'h 15 are blows to head made with enough force to knock head backward; 4. BILL tried to get away by getting off the bed, but Bethea prevented him, whereupon BILL became clearly agitated, engaging in repetitive behaviors and rocking back and forth; 5. Martineau, Manasas Santiago and FT 8 Patrick O?Brien were present during and witnessed Bethea?s abuse, but they failed and refused to stop or report it. At various times on or about February 28: 1. FTS Carl Benjamin, Patrick O'Brien and FTS Lance Camby sat with their feet on BILL's bed; 2. Camby fell asleep while on duty; 3. O?Brien threw sheets at BILL. At various times on or about March 1: 1. FT Lance Camby bent over bed in close proximity to face, raised his right hand, and hit BILL in the head, which abuse was witnessed by two other WHITING staff members, both of whom failed to stop or report it; 2. for a period of one hour and forty minutes, WHITING staff - including Presnick, Greg Giantonio and FT 8 Lance Camby put BILL in 4- point mechanical restraints with no documented justification; 3. Camby entered BILL's room eating a plate of food, than repeatedly used a spoon to launch the food at face; 16 9. the food landed on BILL's bed and was then eaten by him; Defendant C.E.O. of Connecticut Valley Hospital, later admitted in the course of an investigation by the United States Department of Health and Human Services Centers for Medicare Medicaid Services (CMS) that the plate of food was intended for BILL, and that Camby?s behavior ?was an abusive act and should not have occurred"; FTS Greg Giantonio and FTS Patrick O?Brien threatened BILL with raised fists and other fighting type gestures; FTS Bruce Holt and another FTS sat with their feet on BILL's bed, eating sunflower seeds; Quider repeatedly kicked and pushed BILL until he finally fell out of bed onto the floor; BILL got up and back into bed, and Quider kicked him again in his torso; 10. Carl Benjamin was present during and witnessed Quider?s abuse, but he failed and refused to stop or report it. At various times on or about March 3: 2. Ftobert Martineau raised his hand and hit BILL in the back; FTS Clayton Davis witnessed the assault, but failed and refused to stop or report it; Martineau repeatedly kicked BILL while Nurse Cusson watched; Cusson then repeatedly kicked BILL and Martineau joined in; Carl Benjamin repeatedly kicked 6. FTS Clayton Davis and FTS Greg Giantonio were present during and witnessed Benjamin's abuse, but they failed and refused to stop or report it; 7. Cusson repeatedly kicked BILL for about two minutes while BILL was lying in bed; 8. Cusson straddled BILL's head, placed his legs around neck in a scissor-like leg lock, and squeezed, while leaning forward and forcibly punching or pushing body; 9. a few minutes later, Cusson pulled the sheets from bed, kicked BILL multiple times, restrained BILL by putting his legs around BILL's body and holding him down, and then shoved mattress to the floor; 10. FTS Robert Martineau was present during and witnessed Cusson?s abuse, but he failed and refused to stop or report it; 11.during Cusson's abuse, FTS Benjamin shined a flashlight on bed, revealing BILL in distress, but Benjamin failed and refused to stop the abuse or render assistance; 12.after Cusson kicked BILL's mattress to the floor, BILL stood in the comer while Cusson sat with his feet on the bed frame; 13. FTS Clayton Davis touched BILL on the head three times while circling the bed, causing BILL extreme agitation; 14. Davis forcibly shoved BILL down onto the bed; 15.Cusson followed BILL around the room repeatedly touching him, causing BILL to be visibly upset, agitated and retreating; TB 16.Camby repeatedly threw food at BILL, and spit food onto shirt, bed and pants, which BILL then ate, while FTS Larned and another FTS watched; 17. FTS Quider put his feet on bed, with one foot touching arm, and used his feet to repeatedly tug on sheets. At various times on or about March 4: 1. FTS Benjamin repeatedly kicked BILL, threatened to snap a towel at BILL, poked BILL with his shoe, and repeatedly kicked mattress from the bed frame as BILL attempted to place it back; FTS Ftobert Jones, FTS Daniel DeJesus, FTS Seth Quider and Owen Hughes were present during and witnessed Benjamin?s abuse, but they failed and refused to stop or report it; FTS Quider, while sitting on a chair next to BILL, who is lying in bed, kicked BILL multiple times, then draped his legs over BILL's chest while BILL thrashed his lower limbs; FTS Daniel DeJesus was present during and witnessed Quider?s abuse, but he failed and refused to stop or report it. At various times on or about March 5: 1. Forensic Nurse Michael Presnick put both feet on newly changed sheets; BILL ate objects off the floor while two Forensic Treatment Specialists watched and did nothing; 19 Presnick tormented BILL by repeatedly touching his arms, head and legs. and by threatening him with a fighting stance; FTS Patrick O'Brien was in the room for much of the abuse, but was asleep in a chair. At various times on or about March 6: 1. Quider slept in a chair with his feet on bed while BILL objected; FTS Quider dropped his leg onto BILL as soon as BILL settled down, then kicked BILL in the shoulder; FTS Clayton Davis was present during and witnessed Quider?s abuse, but he failed and refused to stop or report it; Nurse Cusson tormented BILL by circling the bed and touching him while BILL tried to defend himself and FTS Benjamin watched; FTS Benjamin and Forensic Nurse Cusson kicked BILL repeatedly while BILL lay in bad, then pinned BILL to the mattress by putting their legs and feet across his body; Cusson hit Cusson wrapped his legs in a scissor-like leg look around head and neck, forcing BILL down onto the bed; FTS Davis tormented BILL by moving around in the dark on the far side of the room; FTS Seth Quider repeatedly hit and poked BILL in the head; 2D 10. FTS Aaron Hramiak was present during and witnessed some or all of the abuse, but he failed and refused to stop or report it. At various times on or about March 7: 1. FTS Benjamin kicked BILL multiple times with both feet while BILL lay in bed; Benjamin kicked BILL as Cusson pulled the sheets off BILL's bed; FTS O'Brien was present during and witnessed Benjamin?s abuse, but he failed and refused to stop or report it; Cusson grabbed BILL, covered his face with a bed sheet, and pulled his arms and leg; BILL was plainly agitated and, while Cusson menacingly circled the bed, BILL tried to protect himself by rolling from side to side and thrashing; Cusson then pulled the sheet over head a second time and held him down, then left the room; Cusson returned with a cup of an unknown liquid, and, while FTS Benjamin sat with his feet on bed, and BILL was lying down, he poured the liquid over head; BILL jumped up, flinching and retreating, and spilling the liquid onto the floor; Cusson pulled the sheets from BILL's bed and used them to wipe the liquid on the floor while leaning over the bed causing BILL to reel from Cusson?s contact; 21 10.Cusson brought a mop and rolling bucket into BILL's room, mapped the floor, then repeatedly took the dirty, wet m0p out of the bucket and put it on head, moving the mop back and forth with a jabbing motion; 11.FTS Benjamin kicked mattress onto the floor; 12. FTS Camby picked up a bed sheet and hit BILL in the face with it; 13.Camby kicked mattress near his leg; 14. Martineau, FTS O?Brien, FTS Giantonio and Benjamin were present during and witnessed Cusson's abuse, but they failed and refused to stop or report it. At various times on or about March 8: 1. FTS Benjamin put his feet on head while BILL lay in bed; 2. FTS O?Brien put his feet on BILL's bed while BILL was sleeping; 3. FTS Camby taunted, kicked and hit BILL repeatedly while BILL lay in bed; 4. Camby grabbed arm and kicked BILL's left leg; 5. a WHITING housekeeper threatened BILL with a dry mop while BILL lay in bed; 6. Camby threw a cup of liquid on BILL while he lay in bed; 7. FTS Floberl Larned was present during and witnessed Camby?s abuse, but he failed and refused to stop or report it; 8. Larned also taunted BILL with an eating utensil while a Forensic Nurse watched; 9. Camby dropped food from a cup onto BILL while he lay in bed; 10.staff failed and refused to intervene while BILL ate a paper envelope; 22 11.FTS Camby, O?Brien and FTS Davis repeatedly pulled sheets off of him; 12. Davis threw a sheet at BILL and raised his feet and kicked BILL twice; 13. Davis repeatedly taunted BILL with a folded paper towel. At various times on or about March 9: 1. 2. 9. FTS Clayton Davis kicked BILL repeatedly while BILL sat on the bed; FTS Giantonio was present during and witnessed Davis?s abuse, but he failed and refused to stop or report it; Giantonio put his foot against head and kicked him repeatedly; Benjamin and Aaron Hramiak taunted BILL while he lay in bed; Cusson repeatedly kicked BILL in the head and body, and slapped head, while BILL was laying down and Giantonio watched; Benjamin put his feet on head; FTS Benjamin stuck a rolled-up piece of paper into left ear while he slept; FTS Giantonio was present during and witnessed Benjamin?s abuse, but he failed and refused to stop or report it; Giantonio also kicked BILL repeatedly; 10.Cusson kicked BILL repeatedly, pulled the sheet away from BILL and threw it at him; 11.Cusson taunted BILL by using his feet to lift the comer of the mattress and bounce it several times, then put his foot on top of head. At various times on or about March 10 and 11: 23 8. 9. . Cusson lunged at BILL with an open hand and hit him in the head while BILL was lying down; Davis raised his hand at BILL and taunted him while BILL was sitting in bed; Camby taunted BILL by repeatedly slamming his chair into BILL's bed; Camby threw soda onto head and body; Nurse Presnick sprayed BILL in the face with an aerosol can; FTS Larned entered room, pulled a sheet over head and tucked it around head and body, then left; sitting in chairs at the door to room when Presnick sprayed BILL in the face were FTS Thomas Lee and FTS Michael LaBarge, both of whom failed and refused to come to aid or to report the abuse; Camby threw an object at Camby and Robert Larned kicked 10. FTS Christian Todzia and FTS Michael Kirdzik were present during and witnessed Camby?s abuse, but they failed and refused to stop or report it; 11.FTS Davis put a towel and sheet around neck and over his face; 12. Davis later rolled into BILL's room on a chair and kicked him, then taunted BILL by repeatedly touching him; 13. FTS Marlon Saunders and Joseph Lewis were present during and witnessed Davis's abuse, but they failed and refused to stop or report him; 14.Cusson tormented BILL by touching and hugging him, causing BILL to appear to be in pain; 24 15.as soon as BILL stopped reacting, Cusson tormented him again; 16.Cusson struck BILL in the head with a TV remote, making BILL reel forward, while Larned watched; 17. Larned and Camby grabbed and kicked 18.Camby threw food at BILL, hitting him in the head; 19.the food rolled onto the floor, and Camby picked it up and threw it on BILL's bed; 20.Camby shoved food in BILL's face; 21 .Camby threw food on sheets as Larned watched; 22.Larned taunted BILL by moving the bed with his foot; 23.FTS Martineau sat with his feet on the bed near BILL's head; 24.Cusson hit and touched BILL repeatedly; 25. FTS Bethea touched BILL and pulled the sheet off of him, causing BILL to rock back and forth in distress, while Larned and another FTS watched; 26.Cusson grabbed BILL and pushed him down onto the bed, pulling BILL's shirt off his shoulder and ripping it; 27. while BILL sat in bed, Cusson shoved his buttocks in BILL's face, then climbed into bed, straddled face with his crotch, and humped face; 28. after he got off the bed, Cusson again shoved his buttocks in face; 29.FTS Martineau and FTS Bruce Holt and/or Larned were present during and witnessed Cusson?s abuse, but they failed and refused to stop or report it; 25 30. FTS Larned sat on a chair beside body and tapped head with his foot, causing BILL to jump up in agitation; 31. FTS Giantonio was present during and witnessed Larned?s abuse, but he failed and refused to stop or report it; 32.Giantonio repeatedly touched and hit BILL's head and face, causing BILL to be visibly agitated; 33.Benjamin repeatedly touched and taunted BILL, causing BILL to rock back and forth in bed. At various times on or about March 12: 1. FTS Benjamin put his feet on BILL's bed; 2. FTS O?Brien kicked 3. FTS Giantonio wheeled his chair toward bed and kicked him, then kicked the mattress until it was hanging off the bed while O?Brien trapped BILL behind the bed; 4. none of the staff assisted BILL with putting the mattress back on the bed; 5. Benjamin repeatedly shined a flashlight in face; 6. a total of five WHITING staff were in the room while BILL was visibly upset, and no one came to his aid; 7. Cusson jumped up from his chair and forced BILL, who was sitting, to lie flat on his bed; 8. Cusson kicked mattress; EB 9. FTS Giantonio and/or Cusson kicked BILL off the bed, forced him to lie on the floor, took turns poking and shoving him, then put their shoes on mattress and shook and flipped it off the bed onto the floor; 10. FTS O'Brien was present during and witnessed some or all Giantonio?s and Cusson?s abuse, but he failed and refused to stop or report it; Camby sipped from and/or spit in drink, and put his feet on bed. At various times on or about March 13: 1. FTS Quider rolled his chair around BILL's room repeatedly kicking BILL's arm every time he attempted to drink from a cup, causing the liquid to spill onto the floor; Quider repeatedly kicked BILL, and put his leg on BILL, as BILL sat in bed; Presnick and FTS Adetunji Olawale were present during and witnessed Quider?s abuse, but they failed and refused to stop or report it; Presnick walked to the back of bed and grabbed him around the neck; Quider ripped the sheet away from BILL while Camby watched and laughed; BILL picked up paper off the floor and put it in his mouth, and no one came to his aid; FTS Stocking threw folded paper at Davis grabbed arm and pulled on him. 2? At various times on or about March 14: 1. FTS Davis circled BILL's bed shining a flashlight into eyes waking him up; Davis repeatedly pushed BILL down onto the bed; FTS Benjamin and FTS Giantonio were present during and witnessed Davis?s abuse, but they failed and refused to stop or report it; Davis and Benjamin simultaneously kicked BILL for seven minutes; Davis repeatedly taunted, poked and pulled an FTS threw a soiled napkin at FTS Bethea came into BILL's room and pulled the sheet off of him while he was sleeping; Camby pulled the sheet off of BILL, then touched neck and/or back, causing BILL to reel. At various times on or about March 15: 1. 2. Camby pulled the sheet off of Camby put a towel over head and put his leg and foot on top of an FTS repeatedly threw chips at BILL and onto the bed; that same FTS touched and grabbed BILL and threatened him with raised lists; that same threw cookies onto bed; Presnick gave BILL a partially-eaten cookie; 28 . FTS Bruce Holt, from a standing position, kicked BILL multiple times while he lay in bed; . Cusson and FTS Lamed were present during and witnessed Holt?s abuse, but they failed and refused to stop or report it. At various times on or about March 16: 1. FTS Quider disturbed BILL with fluid, causing BILL to jolt up in bed, frantically move about the bed, and cry into his sheets; . FTS Benjamin repeatedly kicked BILL while BILL tried to defend himself; . Benjamin pulled sheets while BILL was asleep; . Benjamin hit BILL in the head; . FTS Giantonio tormented BILL while he tried to sleep; . Cusson was present during and witnessed Giantonio's abuse, but he failed and refused to stop or report it; . FTS Benjamin put his legs and feet on BILL to hold him down, while Cusson watched; . Cusson pushed BILL up and down on the bed; . FTS Lamed poked and prodded shoulders, then put his shoes on head and face while BILL lay in bed; 10. FTS Justin Hart and FTS Stephan Keller were present during and witnessed Larned?s abuse, but they failed and refused to stop or report it; 11.FTS Davis hit BILL on the face and head with a rolled-up folder, then Davis and FT Lamed pushed BILL down onto the bed; 12. Davis taunted BILL by pushing and pulling on him; 29 13. FTS Lance Camby, FTS Hart and Keller were present during and witnessed Davis?s and Larned?s abuse, but they failed and refused to stop or report it; 14.Camby pushed BILL in the chest and repeatedly and constantly touched shoulder and back causing extreme agitation; 15. Davis repeatedly tapped and hit BILL until BILL fell back in bed and covered himself with his arms; .16. Larned repeatedly touched BILL's head with a sneaker while another FTS watched; 17. Larned put his feet on the mattress on either side of head and pushed down on head and cheeks while another FTS watched. At various times on or about March 17: 1. Cusson threw sheets on the floor, then sat in a chair next to BILL's bed and pushed and kicked him, including kicking him in the head, until finally kicking him and his mattress onto the floor; 2. as BILL repeatedly attempted to replace the mattress, Cusson and Benjamin kicked the mattress back onto the floor; 3. FTS Bethea sat on bed, repeatedly poking and prodding him, then grabbed ahold of shirt and pushed him down onto the bed; 4. while sitting on a chair beside bed, Bethea repeatedly put his shoes and feet on BILL's head, face and upper body; 3i} Bethea relentlessly tormented BILL by grabbing his pants and shirt, and continuously tapping and touching him and putting a hat on his head and face against his will; Bethea repeatedly poked BILL with a pointy object; FTS Quider put a towel on the back of BILL's neck and pushed him down; FTS Bruce Holt kicked BILL while he was lying in bed; FTS Martineau, Holt and FTS lkenna Uzoka were present during and witnessed Bethea's abuse, but they failed and refused to stop or report it; 10. Bethea was present during and witnessed Holt?s abuse, but he failed and refused to stop or report it. At various times on or about March 18: . FTS Quider ripped BILL's shirt down the back; FTS Stocking repeatedly touched and tormented BILL and repeatedly snapped a towel in his face; Quider forcibly flipped BILL off his bed and threw his mattress on the floor; FTS Jason DeMarco and FTS Stocking were present during and witnessed Quider?s abuse, but they failed and refused to stop or report it. At various times on or about March 19: 1. Quider rolled his chair into room, where BILL lay in bed covered with a sheet, put his feet on bed, then, holding a bottle of liquid, stood up, began shaking BILL, and poured the liquid onto head approximately 10 times over the course of 10 minutes; BILL got out of bed, and Quider poked him until he got back into bed; 31 Quider brought a gallon type container of liquid into room, took sheet and blanket away, raised the container over head and poured the liquid on head intermittently for approximately three minutes; after bed linens were changed, Quider again poured liquid on BILL while he was lying down and then again after he got out of the wet bed; Quider shook mattress, flipping BILL onto the floor; FTS Stocking, FTS Uzoka, FTS DeMarco, FTS Arthur and a WHITING nurse were present during and witnessed Quider?s abuse, but, they failed and refused to stop or report it; FTS Keith Sylvester was also present during or after Quider?s abuse, and he, too, failed to report it. At various times on or about March 20: 1. FTS Camby threw an unknown object at BILL through the open door of BILL's room; the object landed on shoulder as he lay in bed, and BILL placed the object in his mouth; no one came to aid; FTS Benjamin Fiosado was present during and witnessed Camby's abuse, but he failed and refused to report it; while BILL lay in bed, FTS Flobert Larned tapped head with his shoe and grabbed his arm and shoulder; 32 9. Justin Hart was present during and witnessed Larned?s abuse, but he failed and refused to stop or report it; Cusson kicked mattress to the floor while BILL was walking around the room; BILL sat on the floor for 26 minutes until FTS Benjamin finally moved his legs and feet to allow BILL to put his mattress back on the bed; Camby threw food at BILL and swatted BILL with a rolled-up paper; 10. Larned repeatedly touched BILL with his foot; appeared to be crying, while standing and seated, and appeared to cry in his sheets; no one came to his aid. At various times on or about March 21: . Camby kicked BILL's mattress moving it partially off the frame; Larned repeatedly struck face with rolled up papers while a WHITING nurse watched; FTS Camby and Larned forcibly held BILL down while Nurse Presnick forced a diaper on over BILL's sweatpants against his will; Camby then picked up cookies off the floor and threw them at BILL, who was rocking back and forth on the bed and obviously distressed; Camby taunted BILL with the diaper, repeatedly touching him with it as BILL paced the room; Camby ordered BILL back to bed and, while BILL was clearly upset and trying to cover himself with blankets, put the diaper on head like a hat; 33 51. 9. Camby, Larned, Presnick, and a Nurse watched and laughed; a WHITING Forensic Nurse looked into room while the abuse was occurring, then walked away; Presnick and Camby returned later and taunted BILL with the diaper. At various times on or about March 22: 1. 2. FTS Giantonio repeatedly kicked and sheets; Giantonio, at one time, kicked BILL repeatedly, very fast, then landed a few isolated blows without any justification or provocation, as FTS Davis watched; Giantonio taunted BILL by repeatedly attempting to put a cowboy hat on his head; FTS Davis was present during and witnessed Giantonio's abuse, but he failed and refused to stop or report it. On all or virtually all of the above shifts, the Forensic Nurses and Forensic Treatment Specialists responsible for supervision, care and wellbeing talked and texted on their cellphones when they should have been observing and caring for BILL, in violation of the WHITING rules prohibiting the use and possession of cellphones in the facility. 52. Staff's use and possession of cellphones was allowed and encouraged by the WHITING employees who manned the metal detector and wand at the entrance to the facility, by the employees, including agency police officers, who were responsible for monitoring the detector and wanding, and by the employees responsible for viewing the 24/7 video surveillance of room and of the WHITING entrance. 34 53. At the same time that the WHITING Forensic Nurses and Forensic Treatment Specialists were repeatedly and blatantly abusing and torturing BILL, the WHITING staff responsible for completing clinical and treatment records, nursing notes and observation sheets not only intentionally failed to document the abuse, but they deliberately lied about and the course of his illnesses and they falsely accused BILL of refusing treatment, threatening staff, engaging in behaviors and/or exhibiting no behavior of concern and requiring no assistance, thus misleading other members of treatment team, depriving him of needed care and interventions, and causing him extreme mental, emotional and physical suffering. 54. Defendant DMHAS COMMISSIONER later admitted in testimony to the Connecticut Legislature that BILL was subjected to obvious ?physical abuse?, that she?d ?never witnessed anything that extreme", that the abuse was ?pervasive and systematic?, and that she considered the abuse ?a failure of the management at Whiting. The management at Whiting should have known." She also stated in the press that ?[a]ny mistreatment or abuse of clients is unconscionable", and in a public statement that the abuse was ?reprehensible" and ?appalling?, and that, after she viewed the video evidence, it "sickened [her] and has haunted [her] ever since?. 55. Both and DMHAS Chief Operating Officer Paul Dileo admitted in testimony to the Connecticut Legislature that, since the video camera in room transmitted live directly to the Unit 6 nursing station, it was ?surprising that no problems, allegations, transgressions, were noted during an extended period of 35 time." Dileo testified, ?Yes, we were shocked by that"; added, ?Absolutely." 56. At all relevant times, all DMHAS employees, including the defendants, had an absolute and unambiguous obligation to immediately report suspected or actual abuse, neglect or exploitation of WHITING patients, and an absolute and unambiguous obligation to protect the patient and to intervene in such abuse, neglect or exploitation whenever possible. 57. Following the initial report of abuse, and subsequent investigation by DMHAS and law enforcement, the defendants determined that Forensic Nurses Cusson and Presnick, and Forensic Treatment Specialists Quider, Larned, Camby, Martineau, Benjamin, Davis, Giantonio, Holt, and Bethea all violated DHMAS General Work Flule 19 (prohibiting ?physical violence, verbal abuse, inappropriate or indecent conduct and behavior that endangers the safety and welfare of persons or property?). 58. Following subsequent investigation, the defendants also determined that numerous other WHITING staff members, including Forensic Treatment Specialists Daniel DeJesus, Michael Kirdzik, Michael LaBarge, Joseph Lewis, Adetunuji Olawale, Benjamin Ftosado, Marlon Saunders, Keith Sylvester, Ikenna Uzoka, Wayne Stocking, Jason DeMarco, Patrick O'Brien, Christian Todiza, John O?Connell, Christopher Smith, Eric Miner, Aaron Hramiak, Justin Hart, Manases Santiago, Arthur Stephen Keller, Alexander Joseph, and Robert Jones, also violated DHMAS General Work Rule 19 in connection with the abuse of BILL SHEHADI. 35 59. Thus, the defendants themselves have determined that 34 State employees responsible for the care, treatment and supervision of a profoundly mentally ill human being used their taxpayer-funded positions of trust and responsibility to intentionally harm and abuse, and to allow others to intentionally harm and abuse, the patient they were sworn to protect. 60. On April 20, 2017, DMHAS placed defendants WARD-MCKINLAY and KOZAK on paid administrative leave for violation of State Personnel Regulations 5- 1) (prohibiting ?neglect of duty, or other employment related misconduct") and DMHAS General Work Fiules. 61. Following investigation, on July 12, 2017, the United States Department of Health and Human Services Centers for Medicare Medicaid Services (CMS) concluded that the defendants had violated 42 (?The patient has the right to be free from all forms of abuse or harassment"). 62. In the course of the CMS investigation, defendant admitted that the Forensic Nurses? and Forensic Treatment Specialists? abuse of BILL was ?egregious with willful disregard of the hospital?s abuse policies?, and that the staff assigned to observe and care for BILL ?failed to report multiple incidents of disrespectful behaviors, abuse, neglect, and patient exploitation because the staff themselves were complicit with the acts." 63. In the course of the CMS investigation, defendant KOZAK, the WHITING Chief of Patient Care Services, admitted that she "had seen staff abuse and other staff fail to report witnessing abuse.? 3? 64. On March 21, a WHITING employee reported to defendant KOZAK that staff were abusing BILL by kicking and bullying him, replacing his lotion and shampoo with hand sanitizer, dumping salt in his coffee, and contaminating his food with hot sauce. 65. CMS concluded that defendant KOZAK and defendant WARD-MCKINLAY were on actual notice of abuse allegations at least as of 4 pm. on March 21, but they failed to ensure that BILL was free of contact with the identified abusers until the abusers were placed on leave on March 22. 66. Cusson, Benjamin, Quider, Larned, Camby, Davis, Giantonio, Holt and Bethea were subsequently arrested and charged with multiple counts of Cruelty to Persons in violation of Conn. Gen. Stat. and multiple counts of Disorderly Conduct in violation of Conn. Gen. Stat. 53a-182. Presnick was also subsequently arrested and charged with Cruelty to Persons in violation of Conn. Gen. Stat. 53- 67. The video tapes of room prior to February 27, 2017 were intentionally taped over, but similar acts of abuse, humiliation and torture were inflicted on BILL by his caregivers in the weeks, months and years preceding that date. 68. In a June 12, 2008 letter to Dr. Michael Norko, Medical Director of WHITING, BILL stated am thrown in the blue room and beaten up in the bathroom and in the blue room when I need to get water"; ?please help me as I am constantly picked on?; and ?Mark Cusson is trying to kill me". Neither Norko nor any of the defendants responded to plea for help. 33 69. In a letter to a WHITING doctor dated October 12, 2006, BILL wrote: need my sitters as I am extremely lonely, but I don?t like being abused or humiliated. Today when I was put in seclusion I was humiliated, threatened and abused. Chris Markovitz threatened to kill me and beat me up Americo Novu)"; ?Wayne Stocking . . . threw a cup of water on my chest"; do not feel I am loved"; and don?t like being abused". 70. On March 22, 2017, following allegations of abuse from several members of the WHITING Service staff, the defendants transferred BILL from WHITING Unit 6 to Unit 4. He remains on continuous 24/7 staff observation status with two male staff. 71. At all times mentioned herein, each defendant was acting in the course and scope of his or her employment. 72. At all times mentioned herein, each defendant was acting under color of law. 73. The individual defendants were, in multiple ways, personally involved in and responsible for the abuse inflicted on BILL: a. They were grossly negligent in supervising the Forensic Nurses and Forensic Treatment Specialists and other WHITING staff who abused, neglected and exploited b. They created policies and customs, and allowed the continuance of policies and customs, that permitted Forensic Nurses, Forensic Treatment Specialists and other staff on Unit 6 to inflict physical and abuse on BILL and to neglect and exploit him, and (ii) permitted and/or encouraged WHITING employees to look the other way and to remain silent when they knew 39 and should have known that physical and abuse, neglect and exploitation was occurring; and 0. They exhibited deliberate indifference to BILL's rights by failing to act on information indicating that unconstitutional acts, including the abuse, neglect, exploitation and the cover-ups, were occurring. 74. The defendants were deliberately indifferent to safety and care, and to the inhumane conditions of his confinement; they acted intentionally and/or they recklessly failed to act with reasonable care even though they knew or should have known that BILL was subjected to an excessive risk of harm. 75. The defendants? deliberate indifference was outrageous and egregious under the circumstances. 76. The defendants? deliberate indifference shocks the conscience and constitutes a violation of substantive due process rights. 77. The defendants deprived BILL SHEHADI of his rights under the Fourteenth Amendment to reasonable care and reasonably safe conditions of confinement, and they are liable for redress pursuant to 42 U.S.C. 1983. COUNT TWO (Violation of the Fourteenth Amendment?s Guarantee of the Flight to Be Free from the Use of Excessive Force by State Agents and Employees, against defendants Delphin-Ftittmon and Vartelas in their official capacities for injunctive relief, and against defendants Delphin-Fiittmon, Vartelas, Ward-McKinlay, Kozak, Birkbeck, Uyanwune-Clark, Candelaria, Stout, Bartnicki, Guitard, Vallejo, and Tilley in their :ngclaitggual capacities for compensatory and punitive damages, pursuant to 42 U.S.C. 1. Paragraphs 1-77 of Count One are hereby incorporated and realleged as Paragraph 1 of Count Two. 4o 2. The defendants were deliberately indifferent to the use of excessive force against BILL SHEHADI by State agents and employees; they acted intentionally and/or they recklessly failed to act with reasonable care even though they knew or should have known that BILL was subjected to an excessive risk of harm. 3. The defendants? deliberate indifference was outrageous and egregious under the circumstances. 4. The defendants? deliberate indifference shocks the conscience and constitutes a violation of BILL substantive due process rights. 5. The defendants deprived BILL SHEHADI of his right under the Fourteenth Amendment to be free from the use of excessive force by State agents and employees, and are liable for redress pursuant to 42 U.S.C. 1983. COUNT THREE (Violation of the Fourteenth Amendment?s Guarantee of the Flight to Reasonable Medical and Mental Health Care, against defendants Delphin-Ftittmon and Vartelas in their official capacities for injunctive relief, and against defendants Delphin- Fiittmon, Vartelas, Ward-McKinley, Kozak, Birkbeck, Uyanwune-Clark, Candelaria, Stout, Bartnicki, Guitard, Vallejo, and Tilley in their individual capacities for compensatory and punitive damages, pursuant to 42 U.S.C. 1983): 1. Paragraphs 1-77 of Count One are hereby incorporated and realleged as Paragraph 1 of Count Three. 2. The defendants were deliberately indifferent to BILL SHEHADI's right to reasonable medical and mental health care; they acted intentionally and/or they recklessly failed to act with reasonable care even though they knew or should have known that BILL was subjected to an excessive risk of harm. 3. The defendants? deliberate indifference was outrageous and egregious under the circumstances. 41 4. The defendants? deliberate indifference shocks the conscience and constitutes a violation of BILL substantive due process rights. 5. The defendants deprived BILL SHEHADI of his right under the Fourteenth Amendment to reasonable medical and mental health care, and are liable for redress pursuant to 42 U.S.C. 1983. COUNT FOUR (Violation of the Fourteenth Amendment?s Guarantee of the Flight to Protection from Harm, against defendants Delphin-Fiittmon and Vartelas in their official capacities for injunctive relief, and against defendants Delphin-Ftittmon, Vartelas, Ward- McKinlay, Kozak, Birkbeck, Uyanwune-Clark, Candelaria, Stout, Bartnicki, Guitard, Vallejo, and Tilley in their individual capacities for compensatory and punitive damages, pursuant to 42 U.S.C. 1983): 1. Paragraphs 1-77 of Count One are hereby incorporated and realleged as Paragraph 1 of Count Four. 2. At all times relevant to this Complaint, the defendants had and have a constitutional obligation to provide BILL SHEHADI protection from harm because they had a reasonable opportunity to intervene, they had a special relationship with him, and they affirmatively created and increased the opportunity for the Forensic Nurses, Forensic Treatment Specialists and other State employees to harm him. 3. The defendants were deliberately indifferent to BILL right to protection from harm; they acted intentionally and/or they recklessly failed to act with reasonable care even though they knew or should have known that BILL was subjected to an excessive risk of harm. 4. The defendants? deliberate indifference was outrageous and egregious under the circumstances. 42 5. The defendants? deliberate indifference shocks the conscience and constitutes a violation of BILL substantive due process rights. 6. The defendants deprived BILL SHEHADI of his right under the Fourteenth Amendment to protection from harm, and are liable for redress pursuant to 42 U.S.C. 1983. COUNT FIVE (Violation of the Patients? Bill of Rights, Conn. Gen. Stat. 17a-541, against the State of Connecticut, DMHAS, and Whiting for injunctive relief and compensatory damages, and against all individual defendants in their individual capacities for compensatory and punitive damages): 1. All paragraphs of Counts One through Four are hereby incorporated and realleged as Paragraph 1 of Count Five. 2. At all relevant times, defendants WHITING FORENSIC DIVISION OF CONNECTICUT VALLEY HOSPITAL and WHITING FORENSIC HOSPITAL are and were ?Facilities" within the meaning of Conn. Gen. Stat. 3. At all relevant times, BILL SHEHADI is and was a "patient?, a ?person with disabilities?, and an ?involuntary patient? within the meaning of Conn. Gen. Stat. (3) and (5). 4. As the Probate Cou rt-appointed conservator of BILL estate, plaintiff ALBERT B. SHEHADI has the authority to bring this suit on behalf, and is a person aggrieved by violations of the Patients? Bill of Rights who may petition the Superior Court for injunctive relief and may bring a civil action for damages, pursuant to Conn. Gen. Stat. 17a-550. 5. The Patients? Bill of Rights, Conn. Gen. Stat. 17a-541, provides that patient hOSpitalized or treated in any public or private facility for the 43 treatment of persons with disabilities shall be deprived of any civil rights except in accordance with due process of 6. The freedom from deprivation of ?any civil rights" provided in Section 17a- 541 incorporates the freedom from deprivation of ?any rights, privileges or immunities secured by the Constitution" as guaranteed under 42 U.S.C. 1983, including the rights: to safety and reasonable care; to humane conditions of confinement; to be free from the use of excessive force by staff; to reasonable medical and mental health treatment; and to protection from harm, all guaranteed by the Due Process Clause of the Fourteenth Amendment. Mahoney v. Lensink, 213 Conn. 548, 570 (1989). 7. Defendants VARTELAS, WARD-MCKINLAY, KOZAK, BIRKBECK, UYANWUNE-CLAFIK, CANDELAFIIA, STOUT, BARTNICKI, VALLEJO, and TILLEY are liable in their individual capacities for compensatory and punitive damages because they showed a reckless disregard of the just rights and safety of BILL SHEHADI and of the consequences of their acts and omissions. As such, they engaged in wanton, reckless and malicious conduct. 8. The defendants deprived BILL SHEHADI of his civil rights in violation of Conn. Gen. Stat. 17a-541, and are liable for redress pursuant to Conn. Gen. Stat. 17a-550. COUNT SIX (Violation of the Patients? Bill of Flights, Conn. Gen. Stat. 17a- 542, against the State of Connecticut, DMHAS, and Whiting for injunctive relief and compensatory damages, and against all individual defendants in their individual capacities for compensatory and punitive damages): 1. Paragraphs 1-8 of Count Five are hereby incorporated and realleged as Paragraph 1 of Count Six. 44 2. The Patients? Bill of Rights, Conn. Gen. Stat. 17a-542, provides that ?[e]very patient treated in any facility for treatment of persons with disabilities shall receive humane and dignified treatment at all times, with full respect for his personal dignity and right to privacy." 3. The defendants deprived BILL SHEHADI of his rights to humane and dignified treatment and respect for his personal dignity and right to privacy in violation of Conn. Gen. Stat. 17a-542, and are liable for redress pursuant to Conn. Gen. Stat. 17a-550. COUNT SEVEN (Violation of the Patients' Bill of Ftights, Conn. Gen. Stat. 17a-542, against the State of Connecticut, DMHAS, and Whiting for injunctive relief and compensatory damages, and against all individual defendants in their individual capacities for compensatory and punitive damages): 1. Paragraphs 1-8 of Count Five are hereby incorporated and realleged as Paragraph 1 of Count Seven. 2. The Patients? Bill of Flights, Conn. Gen. Stat. 17a-542, provides that ?[e]ach patient shall be treated in accordance with a specialized treatment plan suited to his disorder." 3. The defendants deprived BILL SHEHADI of his right to be treated in accordance with a specialized treatment plan suited to his disorder in violation of Conn. Gen. Stat. 17a-542, and are liable for redress pursuant to Conn. Gen. Stat. 17a-550. COUNT EIGHT (State Common Law Recklessness against the individual defendants in their individual capacities for compensatory and punitive damages): 1. All paragraphs of Counts One through Seven are hereby incorporated and realleged as Paragraph 1 of Count Eight. 45 2. The defendants were consciously aware of the fact that they created and/or allowed a substantial risk to BILL SHEHADI. 3. Notwithstanding the defendants? conscious awareness of the risk to BILL, they failed to take necessary and appropriate steps to reduce or eliminate the risk. 4. Notwithstanding the defendants? conscious awareness of the risk to BILL, they took affirmative steps to exacerbate the risk and to make harm and injury to BILL more likely. 5. The defendants? conduct showed a reckless disregard of BILL's just rights and safety and of the consequences of their actions, was unreasonable, and involved an extreme departure from ordinary care in a situation where a high degree of danger was apparent. 6. The reckless and callous indifference, and the wanton misconduct, of the defendants, alone and in concert, caused BILL to be mentally and physically abused, neglected, exploited, assaulted, harassed, humiliated and tortured, and caused the deprivation of his Constitutional rights and his rights under the Patients? Bill of Rights. COUNT NINE (State Common Law Intentional Infliction of Emotional Distress against the individual defendants in their individual capacities for compensatory and punitive damages): 1. All paragraphs of Counts One through Eight are hereby incorporated and realleged as Paragraph 1 of Count Nine. 2. The defendants intended to inflict emotional distress or they knew or should have known that emotional distress was the likely result of their conduct. 3. The defendants' conduct was extreme and outrageous. 46 4. The defendants? conduct, alone and in concert, caused distress. 5. The emotional distress sustained by BILL was and is severe. ALLEGATIONS RE. INJUNCTIVE RELIEF 1. All paragraphs of Counts One through Nine are hereby incorporated and realleged here. 2. Absent the requested injunctive relief, BILL SHEHADI will suffer imminent and substantial irreparable injury. 3. BILL SHEHADI has no adequate remedy at law. WHEBEFORE, the plaintiff prays for relief as follows: 1. Compensatory damages according to proof; 2. State law punitive damages; 3. Federal law punitive damages; 4. Costs and reasonable attorneys? fees pursuant to 42 U.S.C. 1988; 5. Permanent injunctions against defendants STATE OF CONNECTICUT, DMHAS, WHITING, and VAFITELAS enjoining them from further violations of BILL Constitutional, statutory and common law rights, and requiring them: a. to provide to BILL SHEHADI humane, dignified, safe, and appropriate medical and mental health treatment, care, supervision and conditions of confinement for as long as required by his medical and conditions, and at a location of confinement that is least restrictive and maximally 4? therapeutic. If the defendants cannot provide and ensure the continuation of such conditions of care and confinement at WHITING, they shall move BILL to a facility that meets these standards of care and all applicable constitutional and legal requirements; b. to provide to BILL medical and treatment and care, consistent with constitutional and statutory requirements and the applicable standards of care, including treatment specifically addressing the abuse, neglect and exploitation inflicted on him during his confinement; c. to ensure 24/7 live video and audio surveillance and contemporaneous monitoring of room and residence - whether at WHITING or, if necessary, at another facility - by persons who are trained to identify abuse, neglect and exploitation and who are required to immediately report any actual or suspected abuse, neglect or exploitation to the Commissioner of d. to review, at intervals of no more than seven days, at least 10 random 20-minute portions of the video- and audio-tapes from the previous week, such review to be done by the WHITING Director or Acting Director and/or the Chief of Patient Care Services if BILL remains at WHITING, or by the Commissioner of DMHAS if BILL is moved to another facility; e. to retain all video- and audio-tapes of room and residence for a period of not less than three years from the date of creation; f. to provide, implement and enforce training, policies, practices, protocols, and agency and hospital directives necessary to prohibit and punish 4E abuse, neglect and exploitation of patients and to ensure compliance with these injunctions and applicable law; 9. to retain and fairly compensate an independent auditor, who shall be selected by the plaintiff, and who shall have the authority, without notice, to interview BILL and his caregivers, to inspect conditions of confinement, and to review clinical records and the video- and audio-tapes of his room and residence to ensure compliance with all injunctions and legal requirements, and who shall issue reports concerning same to the plaintiff, DMHAS and the State Attorney General?s Office; h. to take all steps necessary to permanently discharge from State employment the Forensic Nurses, Forensic Treatment Specialists and other employees responsible for the abuse, neglect and exploitation inflicted on BILL, including, at a minimum, the Nurses and Specialists identified in this Complaint; i. in the event that one or more of the Forensic Nurses, Forensic Treatment Specialists and other employees responsible for the abuse, neglect and exploitation inflicted on BILL continue to remain employed by the State, to prohibit them from having any responsibilities for, or contact with, BILL, and to prohibit them from ever entering the facility where BILL resides; j. to ensure that each and every one of the employees responsible for care, custody, treatment and supervision work no more than a maximum of 50 hours in any seven-day period; and 49 k. to waive all cost-of-care and other State liens under Conn. Gen. Stat. 17b-222, et seq., and any other applicable law for the period of BILL's confinement in State custody; and 6. Such further relief as the Court deems just and proper. THE PLAINTIFF By Antonio Ponvert Antonio Ponvert Federal Bar No. ct 17516 Kosko? Koskoff Bieder 350 Fairfield Avenue Bridgeport, Connecticut 06604 TEL: 203-336-4421 FAX: 203-368-3244 Email: aponvert@koskoff.com 5D LET wanva CIV BLOB HOHVW AEITIIJ. OOEIHE) 1 OHS EISHFIN 039 'and 0N3 VGNEHEI 0N3 'anlS ELLEIAA 13l- .L-HHS 13L WVIHIW ISNISHHN :lO HOLOEIHICI - 01:19 SNISUHN 3 HOLOEIHICI 0N3 BHVO ONIJJHM SVWOHJ. 3 HOLOEIHICI DNILOV .LV 3 3 AETIVA '3 WVIHIW HEINOISSIWWOO 9NLLIHM AEITIVA NOISIAICI BNIJJHM BHJ. 1 NOLLOICICIV CINV 3 EIHJ. EIJ.V.LS EIH.L ICIVHEIHS 'El SIH :lO HOLVAHESNOO EIHJ. CINV AEI CIBAHESNOO INVITIIM 1 EVA 1/17 IEILVCI This matter is within the jurisdiction of the Court. The plaintiff demands money damages vastly in excess of the statutory FIFTEEN THOUSAND and 00/100 DOLLARS excluding attomeys? fees, interest and costs. THE PLAINTIFF By - Antonio Ponvert Esq. Koskoff, Koskoff Bieder, RC. 350 Fairlield Avenue. 5th Floor Bridgeport, CT 06604 Tele: (203) 336-4421 Email: aponvert@koskoff.com Juris No. 32250 52 ORDERJREVIEW RE STATE OF CONNECTICUT RECORDED: APPOINTMENT OF CONSERVATOR (For Use Only When a Hearing Has Not Been Held) COURT OF PROBATE PC-3 62A REV. IOKOS COURT OF PROBATE, Middletuwn Probate District DISTRICT NO. PD 15 IN THE MATTER OF William Shehadi, (95-3090) REFERRED TO AS THE CONSERVED PERSON CONSERVATOR OF THE ESTATE [Name address, zip code. and OR OF THE PERSON [Name address, zip code, and telephone number.] teiephone number.) Albert B. Shehadi, 2? Bryam Shore Road, Greenwich, CT 06830. Albert B. Shehadi, Bryam Shore Road, Greenwich, CT (203)531-7711 06830, WRITTEN REPORTS AS TO THE CONDITION OF THE CONSERVED PERSON NAMED ABOVE FROM THE CONSERVED CONSERVATOR AND A PHYSICIAN LICENSED TO PRACTICE MEDICINE IN THIS STATE, AS REQUIRED BY C.G.S. have been ?led in Court, copies of which have been sent to the conserved person and the attorney for the conserved person. The attorney has noti?ed the Court that he or she has met with the conserved person, and a hearing is not requested. Having reviewed the written reports. the Court has determined that there has been no change in the condition of the conserved person since the last preceding review by the Court, and a hearing on the condition of the conserved person shall not be required. The conservatorship shall be continued with the conservator(s) of the person and estate named above. netting: hedgerow, 61h day anugust, 2013. APP (For Us en Held.) PC-362A CLER