Cynthia Olivero 23 Blurnenthal Dr. Uncasville, CT 06382 ciTY SrtHEHt*s$*H' City of New London City Clerk 181 State Street New London, CT 06320 1819fi$ulB gT A#2b JSHAIH&H &Y&LA November 18, 2019 DELIVERED VIA HAND DELIVERY Notice of lntention to Comrnence CivilAction l, Cynthia Olivero, hereby give written notice of my intention tc commence a civilaction for Defamation and Breach of Contract against the City of New London. The event took place on or about June 21,2A19. At that time, the Chief of Police Peter Reichard drafted an email to the City's Chief Administrative Officer Steven Fields regarding my employment with the City of New London's Police Department. Reichard made knowingly false statements about me. One such false statement reads, "This employee has been disciplined by the agency prior to rny tenure for releasing confidentialjuvenile information.. . " Reichard goes on to write "and has been the subject of several internal investigations related to the retention and dissemination of agency records..." City Clerk Jonathan Ayala references the "city's knowledge of the improper care of sensitive records when [] was employed by the police department." in his statement requesting that he retain his current employee (i.e. not permitting me to work in his office). The City of New London violated the terns of a settlement agreement dated March 21,2416 when Peter Reichard referenced an investigation related to juvenile information. I was not found guilty of releasing the information; moreover, any and all investigations prior to the date of the settlement agreement were to be .CONFIDENTIAL." Additionally, the agreement states that the parties were to refrain from sealed and marked making disparaging remarks against one another. On October 31,2019,1 became aware that Police Captain Todd Bergeson called me a "pathological liaf' and he claimed that I had unauthorized possession of New London Police files when Bergeson was interviewed by Connecticut State Police Detective Patrick Dwyer regarding an unauthorized disclosure of a New London Police video. ln2Q15, Bergeson did conduct an investigation related to files held in police property. Bergeson's findings regarding my dishonesty were false; in fact, both Bergeson and Reichard were dishonest in the investigation. Moreover, this investigation was included in the terms of the March 21, 2A16 settlement agreement. Bergeson not only slandered me; he violated the agreement by making disparaging remarks. The time of the damages begins July 12, 2019. At which time, I was laid-off frorn employment by the Mayor of the City of New London due, in part, to the false information provided by Police Chief Peter Reichard and Police Captain Todd Bergeson. The place of the damages is my residence. I hereby file this notice with the clerk of such municipality within six months afier such cause of action has accrued. $;*k4*GCynthia L. Olivero State of Connecticut Commission on Human Rights and Opportunities AFFIDAVIT OF ILLEGAL DISCRIMINATORY PRACTICE For CHRO Office Use Onlv Date Filed: Case No: My name is Cynthia Lvnn Olivero And I reside at 23 Biilrnenthal Drive, Uncasville, CT OGS1Z My mailing address is {if different than street address} My telephone number is ihome) nin My email address is cvnth iahronis@qmail- com The respondent is the City of New London, Connecticut ,9afe_ {cell} B6o-G3e-4635 Whose business address is 181 State Street, New London, CT 06320 The aileged discrimination took place in the town/city of N"w t-onaon, C*onec The last discriminatory action took place on or about 24 Jun 2019; 05 Nov 2019 Iwas Eldenied reasonable accommodation on the basis of a disability on or about 24 J*n 2419 I suspended on ar about Iterminated on or about - ffinot recalled on or about 05 Nov 2019 ffilaid off on or about Effective tZ lutZOtg f] demoted on cir about f] poorly evaluated on or about f]sexually harassed on or ah,out f]earning unequal pay on or about [delegated unequal duties on or about f]delegated difficult assignments on or about _ l-l nlaced on probation on or about f given reduced duties on or about fldenied equal services on or about ffidiscriminated against in terms and conditions of HI flother harassed on or about warned on or about I denied a raise on or about fltransferred on or about f] constructively discharged on or about n not hired on or about [V not promoted on or about 05 Nov 2019 I less trained on or about ffiretaliated against on or about 24 Jun2O19 employment on or about 24 Jun2019 on or about And believe that my date of birth: 0g - 12 - 1972 EI"g* 47 disability {lmrurtrv}: M.sclerosis & spine ffiphysical f, learning disability itnrmrtrv) : I mental disorder {torrurrrv} : f] il f] f] fl fl I marital status {irrrurrv}: race {lorrurtrv}: color {torrurtrv}: national origin {torrurtrv}: sexual orientaticn {tnerulrv}: flancestry {torrurlrvi: r identity alienage {tre rurtrv}: or expression flgende, intellectual disability: male female flsex: sex; PHEGNAT,iCY reilgro us creed/c;'eed : {tuerurtrv} L_l I previo usly opposed, filed or flprior eriminal recsrd {state employment only} May 2018 {Na Resoluiion} ffiother Retaliation for prior CHRO complaints'" 21 Mar 2S16 {$ettledi I I fl fl f] assisted Wasfurere in part a reaton in this action. F103 & STATE OF CONNECTICUT COMMISSION ON HUMAN RIGHT$ AND OPPORTUNITIES Directions: if any information is irrelevant write "n/a". lf any information is unknown write "unknown" lf you need to add additional information please add an additional sheet of paper and identify which paragraph it relates to. 1. I worked or applied to work for respondent at the following location: Applied: New London City Clerk; Recreation; Police Department - Worked at NLPD & Senior Center 2. The respondent employs at least 150 people. 3. I began working for the respondent on or abOut: 31 March 2008 Or I applied to work for the respondent On Of abOut: Requested to "bump" 15 June 4. My most 2019 recent job title was/is: $ecretary (New London Senior Center) 5. I believe respondent discriminated against me on 24 June 2019 when I received notification that I would not be permitted to "bump" into another position when my current position at the Senior Center) had been eliminated by the City of New Lcndon. The basis for this denial was (1) false nts made about me by the Chief of Police (Peter Reichard), who had been named in my 2015 CHRO plaint, and (2) the Mayor's (Michael Passero) elaim that he could not meet my medical accommodations. s, too, is false. The accommodations for my Multiple Sclerosis and spinal injury (sustained at work) are inimal and have been accommodated by the City of New London. 6. The following individuals not of my class bases were treated more favorably: of my union has ever been denied the right to bump into another position. (I believe the City has a member of another union; however, that person was not qualified for the other postion.) I am more n qualified for each position that i was eligible to "bump" into. No member 7. For harassment claims only: The person who harassed me was/isf,a supervisor orfla co-worker. I reported the harassment on 2015 and ZALB and as a result of my report : I complained about discrimination and as a result of my report : to CHRO I have faced false allegations of wrongdoings by Chief of Police Peter Reichard, and Police Captain Todd eson, who were boilr named in the 2015 CHRO complaint, which settled in 2AL6. I request that those individuals or entities also be named as Respondents to this action. STATE OF CONNECTICUT COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES 9. disabiltiy claims only: On or about 24 Feb 2015,I was formally diagnosed with Multiple Sclerosis. On or about 2015, I was diagnosed with a spinal compression fracture. Three orthopedic surgeons (mine, the City's and WC Commissioner's) agree the injury was sustained when I fell at work on severely dilapidated concrete I believe the City of New London is aware of my disabilities becasue (1) i gave them written notice my Multiple Sclerosis diagnosis and need for accommodations in (or about) March 2A75; and {2} My spinal njury occurred at work and has required two spinal surgeries. This is an approved WC injury; therefore, the City NL is fullv aware. 10. For disability/reasonable accommodations claims only. I asked the respondent forthe following accommodation(s) to assist me with my disability: Access to an utocked restroom and the use cf a siUstand desk {VariDegk}. I made this request to Personnel & Risk andlorffiin writing on or about Msmt. Elverbatly on or about zols - 2a:s za:s-zo1s respondent responded in the following way . After I made tfre request the accommodated untit24 Jun 2019 I received notice that the City of New London would no loner meet these accommodations. This is absurd work location has access to a restroom that is not obstructed by an exterior lock. {This became necessary after the regtrcom I was given access to had a key lock that didn't work and I urinated on myself twice at work.) The sit/stand ariDesk) has been accommodated bythe Cityforyears. It is necessary due b my spinal injury. The City has been aware nce October ZOLB flrat this is the only remaining necessary accommodatian for this injury. 24 June ZAt9, 11 . For perceived disability claims only: Although I am not disabled, I believe the respondent believed I had the following disabilities: and treated me differently based on what belief in the following way(s): '12. For nreonancy discrimination claims only: I was pregnant from on or about and the respondent knew about my pregnancy because: to The respondent took the following action(s) against me which I believe was based on my pregnancy: 13. For aidino and abettinq claims onlv: I believe the following individuals or entities abetted the respondent in the discrimination I alleged above and their mailing address(es) is/are The actions these individuals took are: 14. Any other information that is important about this case: 2019 was the City of New London's first opportunity to lay me off for my previous complaints, as my prior union contract had a "no lay off" Other positions were eliminated in the previous contract, those employees were afforded the right to "bump" other employees. The City' cohduct is esp€cially egregious becasue they are fully aware that I'm an e)