SUMMONS CML STATE OF CONNECTICUT Rev. 4-16 cos. 51-346, 51?3a7, 51-349, 51?350. 5245a, SUPERIOR COURT 52?48, 52-259, P.B. 34 through 3-23, 8-1, $043 See other side for instructions if amount, legai interest or property in demand, not including interest and costs is iess than $2,500. . . if amount, legaE interest or property in demand, not Including Interest and costs is $2,500 or more. if claiming other relief in addition to or in of money or damages. TO: Any proper of?cer; BY OF THE STATE OF CONNECTICUT, you are hereby commanded to make due and legai service of this Summons and attached Complaint. Address of court clerk where writ and other papers shall be ?led (Number, street, town and zip code) Telephone number of clerk Return Date (Must be a Tuesday) 51-346, 51-350) (with area code) - June 25 2 G19 70 Huntington Street, CT 06320 860 )443 5363 Mon Day Year JudiciaI District A At (Town in which unit is returnable) (6.6.8. 51-346, 51-349) Case type code (See list on page 2) Housing Session was, Major: Minor: 90 For the Plaintif?s) please enter the appearance of: Name and address of attorney, taw firm or plaintiff if ssh-represented (Number, street, town and zip code) Juris number (to be entered by attorney only) Howard, Kohn, Sprague Fitzgerald, LLP, 237 Buckingham Street, Hartford, CT 06126-1708 028': 60 Telephone number (with area code) Signature of Plaintiff (lf self?represented) 860 525-3101 The attorney or law firm appearing for the plai?tiff? 0; the plaintiff if Email address for deiivery of papers under Section 10-13 (if agreed to) self-represented, agrees to accept papers (service) electronicaily in Yes No - this case under Section 10??3 of the Connecticut taractice Book. I [j st@hk3?aw?c?m Number of Plaintiffs: 1 Number or Defendants: 5 Form attached for additional parties Parties Name (Last, First, Middle Initial) and Address of Each party (Number; Street; P.O. Box; Town; State; Zip; Country, if not USA) First Name: Burdick, Alison, Doctor Plaintiff Addressz 35 Guthrie Piece, New London, CT 06320 Additional Name: P-OZ Piaintiff Ad?iressi First Name: Ritchie, 0-01 Defendant Addresm 134 Williams Street, New London, CT 06320 Additionai 'Name: Rivera, Manuel 0-02 Defendant Address: 134 Williams Street, New London, CT 06320 Additionat Name: Martinez, Mirna D433 Defendant Addressz 134 Williams Street, New London, CT 06320 Additional Name: Kate McCoy 0-04 Defendant Address: 134 Wiiliams Street, New London, CT 06320 Notice to Each Defendant 1. YOU ARE BEING SUEB. This paper is a Summons in a lawsuit. The compiaint attached to these papers states the claims that each plaintiff is making against you in this iawsuit. 2. To be noti?ed of further proceedings, you or your attorney must ?le a form called an "Appearance" with the Clerk of the abovemamed 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 untess you receive a separate notice telting you to some 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 beiieve that you have insurance that may cover the claim that is being made against you in this iawsuit, 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-Eine at under "Court Rules." 5. if you have questions about the Summons and Complaint, you should talk to an attorney quickty. The Clerk of Court is not allowed to give advice on tegal questions. Signed (Sign and pro KW) Commissmner 0f the Name of Person Signing at Left Date signed Supenor Court . ?4 2.. Assistant Clerk James F- Suliivan a?f/Z 2? I lithis by a Clerk: For Court Use Only a. The signin has been done so that the Piaintif?s) wiil not be denied access to the courts. File Date b. It is the responsibility of the Piaintif?s) to see that service is made in the manner provided by law. 0. The Clerk is not permitted to give any legai advice in connection with any iawsuit. d. The Clerk signing this Summons at the request of the Piaintit?s) is not responsible in any way for any errors or omissions in the Summons, any allegations contained in the Compiaint, or the service of the Summons or Compiaint. (Page 3 of 2) i certify I have read and Signed (Self?Represents lei Date Docket Number understand the above: <9 5/2 a/ CIVIL SUMMONS CONTINUATION OF PARTIES JD-CV-Z Rev. 9-12 STATE OF CONNECTICUT SUPERIOR COURT First named Ptaintiff (Last, First, Middie initial) Doctor Alison Burdick First named Detendant (Last, First, Middle Initial) Ritchie, Additional Plaintiffs Name (Last, First, Middle initial, if individual) Address (Number, Street, Town and Zip Code) CODE ?I?i 12 ?13 Additional Defendants Name (Last, First, Middie initial, if individual) Address (Number, Street, Town and Zip Code) CODE New London Board of Education 134 Williams Street, New London, CT 06320 FOR COURT USE ONLY - Fife Date Docket number CIVIL. SUMMONS-Continua?on RETURN DATE: JUNE 25, 2019 SUPERIOR COURT DOCTOR ALISON BURDICK .D. OF NEW LONDON V. AT NEW LONDON RITCHIE MANUEL RIVERA MIRNA MARTINEZ KATE MCCOY NEW LONDON BOARD OF EDUCATION MAY 22, 2019 COMPLAINT COUNT ONE: DEFAMATION AGAINST MANUEL RIVERA, MIRNA MARTINEZ AND THE NEW LONDON BOARD EDUCATION 1. The plaintiff, Doctor Alison Burdick Burdick?) is an administrator for the New London Board of Education (?Board of Education?) and New London Public Schools. She resides in New London where she was born and raisedSuperintendent of Schools endorsement from the State Department of Education. 2. The defendant Ritchie is the current Superintendent for the New London Public Schools. 3. The defendant Dr. Manuel Rivera was the Superintendent of the New London Public Schools when a staff member Corriche Gaston sexually preyed on staff and minor students. 4. The Defendant Manual Rivera is currently the Chairman of the New London Board of Education; 5. The Defendant Mirna Martinez is a member of the Board of Education. 3. HOWARD, SPRAGUE FITZGERALD, LLP . 237 STREET - Po Box 261798 - HARTFORD, CT 06126-1798 . (860) 525-3101 - JURIS No. 28160 6. The Board of Education is charged with the responsibility of educating and graduating students in the City of New London. 7. Dr. Burdick was removed from being the principal of Bennie Dover Jackson Middle School and made a pathway director by Defendant Manuel Rivera acting in his capacity of Superintendent of Schools. Once this happened, she did not have a supervisory role over Mr. Gaskin, Ms. Rodriguez, or educational assistants named in the court documents relative to the current issues confronting the New London Public Schools. Maribel Olivero and Lawrence Washington were their supervisors. Maribel Olivero has not been placed on leave. 8. On May 7, 2019 a special meeting of the Board of Education was called. 9. At that meeting the only thing on the agenda was for the Board of Education to go into Executive Session to discuss the following: A pending legal matter and B) A non?certified employee personnel matter and investigation?; 10. The Special Meeting was held at the office of the Superintendent Ritchie with no public comment on the agenda and no access to the public. ll. Defendants Manuel Rivera and Mirna Martinez knew or should have known that the conduct of the Executive Session violated Connecticut General Statutes Section 1?231 et seq in that it included Kate McCoy, Director of Magnet Schools and Kristea Francolino, Secretary to the Board, as well as multiple members of the New London Police Department. Because minutes are not taken in this meeting, a secretary is not an approved member of the session. Kate McCoy has no relevant connection to personnel matters. HOWARD, KOHN SPRAGUE LLP - 237 BUCKINGHAM STREET - no. BOX 261798 - HARTFORD, or 06126-1798 - (860) 525-3101 - JURIS NO. 28160 12. At that Executive Session matters concerning Plaintiff were discussed, notwithstanding the fact that she was not on the agenda and had no notice. 13. On May 7, 2019 Dr. Burdick, was placed on administrative leave for ?disseminating confidential information? via email. No attempt was made to call Dr. Burdick. Before the suspension of the Dr. Burdick, Defendant Ritchie issued an email directing all personnel to fully cooperate with the investigation into the sexual misconduct of Gaskin. She mentioned nothing about warrants being needed to cooperate and provide information to authorities. Superintendent Ritchie did not give further directives on any process being used to communicate with the authorities until after Dr. Burdick asked. 14. The suspension issued by Superintendent Ritchie has been tied to the Gaskin investigation, rather than Dr. Burdick's cooperation with the police. No efforts have been made to disconnect Dr. Burdick from this widely publicized case. 15. Superintendent Ritchie told the Board of Education that an administrator from the Middle School would be placed on leave, but that the leave was unrelated to the Gaskin case. 16. At that May 7, 2019 special meeting of the Board of Education, Manuel Rivera and Mirna Martinez defamed Dr. Burdick by making false statements about her personal and professional integrity. These statements have been repeated in public session, in the news, and on social media. 17. By making such defamatory statements, they have harmed Dr. Burdick?s reputation and caused her severe emotional distress. 3 KOHN SPRAGUE FITZGERALD, LLP - 237 BUCKINGHAM . Po. BOX 261798 - HARTFORD, or 06126-1798 . (860} 5256101 - no. 28160 COUNT TWO: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS AGAINST DEFENDANTS RICHTIE AND THE BOARD OF EDUCATION 1?17. Paragraphs 1 through l7of the Count One are hereby incorporated as paragraphs 1 throughl7 of the Count Two. 18. Defendant Ritchie has organized public events to have a discussion of the Gaskin debacle. l9. Superintendent Ritchie has had a series of public gatherings in which she had allowed parents and members of the public to defame and libel Dr. Burdick and has done nothing to correct these parents and members of the public of their false statements. Superintendent Ritchie made no attempt to stop parents from defaming Dr. Burdick. Superintendent Ritchie did not set any ground rules for these public sessions. 20. A community member held a similar forum with over 100 people in attendance and set up parameters to ensure that no staff members would be defamed and humiliated as Superintendent Ritchie did. 21. Defendant Ritchie knew or should have known that such misconduct will cause Dr. Burdick severe emotional distress. 23. Defendant Ritchie and the Board of Education have a duty not to cause Dr. Burdick severe emotional distress. 24. Defendant Ritchie and the Board of Education has caused Dr. Burdick severe emotional distress and irreparable harm. KGHN SPRAGUE FITZGERALD, LLP - 23? BUCKENGHAM STREET - 9.0. BOX 261798 - HARTFORD, CT 06?26-1?98 6 (860) 525-3303 - JURIS NO. 28160 COUNT THREE: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AGAINST SUPERINTENDENT RITCHIE 1-24. Paragraphs 1 through 24 of Count Two are hereby incorporated as Paragraphs 1 through 24 of Count Three, as if more fully set forth therein. 25. Superintendent Ritchie over the last several months has targeted Dr. Burdick, and has others observe her without permission and has unfairly disciplined Dr. Burdick. 26. Defendant Ritchie has intentionally encouraged parents and members of the public to defame and libel Dr. Burdick and to harm her reputation. 27. Defendant Ritchie?s misconduct is beyond the bounds of all common decency, and had intentionally caused Dr. Burdick severe emotional distress and irreparable harm. COUNT FOUR: RETALIATION IN VIOLATION OF PUBLIC POLICIES AGAINST THE BOARD OF EDUCATION 1?27. Paragraphs 1 through 27 of Count Three are hereby incorporated as Paragraphs 1 through 27 of Count Four, as if more fully set forth therein. 28. Dr. Burdick report defendant Ritchie to the Department of Children and Families for failing to protect the students against sexually deviant behavior of the employees and staff. 29. Dr. Burdick was unfairly disciplined and put on leave in retaliation for making such a report. for cooperating with the police?s investigation, and for seeking training. Such discipline and leave were important violations of public policies. HOWARD, KOHN SPRAGUE FITZGERALD, LLP - 237 BUCKINGHAM STREET PO. BOX 261798 - HARTFORD, CT 06126-1798 - (860) 525-3101 - NO. 28160 COUNT FIVE: DEFAMATION AGAINST KATE MCCOY, DIRECTOR 6 OF MAGNET SCHOOLS 1~l7. Paragraphs 1?17 of Count One are incorporated as Paragraphs l~l7 of the Count Five as if more specifically set forth herein. 18. Kate McCoy is the Executive Director of Magnet Schools for the New London Public Schools District. 19. Defendant McCoy was hired as a teacher by Dr. Burdick before moving to her current Central Office position. 20. Defendant Kate McCoy has engaged in a campaign of defamation against Plaintiff for a period of time; 21. This campaign was calculated to defame Plaintiff for the purpose of hiding McCoy?s complicity in, and failures relative to, the ongoing sexual abuse of a student as well as an environment which allowed such failures to occur. 22. Kate McCoy has sent disparaging text messages about Dr. Burdick during professional meetings and to staff working with Dr. Burdick. 23. Other employees have made statements to Dr. Burdick regarding Ms. McCoy?s public campaign to defame Dr. Burdick such as don?t want her doing the same thing to me that she does to you.? can?t get on her bad side or she will torture me like she is doing to you.? 24. At a public sporting event, Kate McCoy sought out a reporter and shared information regarding the ongoing investigation into Corriche Gaskin. Kate McCoy was not put on administrative leave. 25. Defendant McCoy has on multiple occasions inquired of subordinates as to 6 HOWARD, KOHN SPRAGUE LLP - 237' BUCKINGHAM STREET - PO. BOX 261798 0 HARTFORD, CT 06128-1798 (860) 525-3101 JURIS NO. 28160 the personal life of Dr. Burdick and with whom she may be having a relationship; 26. Defendant McCoy was placed at the middle school by Superintendent Ritchie as ?Support? for the 3 Directors and Assistant Principal that were already in place. Defendant McCoy has decision making authority over all aspects of the school, which Dr. Burdick did not. 27. Dr. Burdick had requested that State Department of Education training pursuant to Connecticut General Statutes Section 17a-101q regarding the prevention and identification of, and response to, child sexual abuse and assault and resources to further student, teacher, and parental awareness regarding sexual abuse be implemented. That request was not approved by McCoy as being ?unnecessary.? 28. Because of defendant McCoy?s false statements, Dr. Burdick?s reputation was damaged and she suffered severe emotional distress. COUNT SIX: NEGLIGENT INF LICTION OF EMOTIONAL DISTRESS AGAINST KATE MCCOY l.-28. Paragraphs i through 28 of Count Five are hereby incorporated as paragraphs 1 through 28 of Count Six, as if set forth fully therein. 29. Defendant McCoy knew or should have known that such misconduct will cause Dr. Burdick severe emotional distress. 30. Defendant McCoy had a duty not to cause Dr. Burdick severe emotional distress. 31. Defendant McCoy caused Dr. Burdick severe emotional distress and irreparable harm. HOWARD, KGHN SPRAGUE LLP - 23? BUCKINGHAM STREET . no. BOX 261798 - CT 06126-1798 - (860) 525-3301 - NO. 28360 COUNT SEVEN: INTENTIONAL INF LICTION OF EMOTIONAL DISTRESS AGAINST KATE 1,-31. Paragraphs 1 through 31 of Count Six are hereby incorporated as paragraphs 1 through 31 of Count Seven, as if set forth fully therein. 32. Defendant McCoy has intentionally encouraged parents and members of the public to defame and libel Dr. Burdiok and to harm her reputation. 27. Defendant McCoy?s misconduct is beyond the bounds of all common decency, and had intentionally caused Dr. Burdick severe emotional distress and irreparable harm. WHEREFORE, the plaintiff Dr. Burdick seeks the following forms of relief: 1. Money damages; 2. Punitive damages; 3. A preliminary injunction ordering that the Superintendent reveal to the public the truth about Dr. Burdick?s non?involvement with Mr. Gaskin; 4. A preliminary injunction ordering the termination of Dr. Burdick leave and immediate return to work as an administrator; and 5. Such other relief as permitted by law. PLAINTIFF, DOCTOR ALISON BURDICK es /Sullivan, Esq. Ho d, Kohn, Sprague FitzGerald 237 Buckingham Street Hartford, CT 06126-1798 Juris No. 028160 Telephone: 860?5253 101; Fax 860-247?4201 HOWARD, KOHN SPRAGUE FITZGERALD, LLP 237 BUCKINGHAM STREET . PO. Box 261798 - HARTFORD, CT 06126-1?98 - (860) 525-3101 . JURIS NO. 28160 RETURN DATE: JUNE 25, 2019 DOCTOR ALISON BURDICK V. RITCHIE MANUEL RIVERA MIRNA MARTINEZ KATE MCCOY NEW LONDON BOARD OF EDUCATION SUPERIOR COURT .D. OF NEW LONDON AT NEW LONDON MAY 22, 2019 STATEMENT OF AMOUNT IN DEMAND The amount in demand, exclusive of interest and costs, is in excess of Fifteen Thousand Dollars PLAINTIFF, DOCTOR ALISON BURDICK Jam . ?fllvan, Esq. ard, Kohn, Sprague FitzGerald 237 Buckingham Street Hartford, CT 06126?1798 uris No. 028160 Telephone: 860?525?3 101 Fax 860?247-4201 ifs HOWARD, KOHN SPRAGUE FITZGERALD, LLP - .ATTORNEYSAFLAW 237 BUCKINGHAM STREET - P.O. BOX 261798 - HARTFORD, CT 061264 798 - (860) 525-3101 - 3URIS NO. 28160