Free Order on Motion to Disqualify - District Court of Connecticut - Connecticut

I Case 3:03-cv-00109-AVC Document 146 Filed 03/08/ 004 Page 1 of 1
1
1
IN THE UNITED STATES DISTRICT COURT 1
DISTRICT OF CONNECTICUT 1
DUTKIEWICZ, et al, CIVIL ACTION NO 3:03-CV·l09 (AVC)
·_,\ Plaint%r ; '
YX I _
1i : 1 .1 1
V- 1 U a .. 1
Tg ' ‘ 1 1
Q TATE OF CONNECTICUT 1
Q) DEP TMENT OF CHILDREN AND 1
iq FAMILIES, etal, 1
Q, Dejizndams i August , 2003
PLAlNTIFF’S MOTION TO DIS UALIFY COUNS
FOR DEFENDANT ANNE JELLISON 1
Pl ' tiffs have made claims against the Bristol Board of Educati (the "board") and an 1
individual efendant Anne Jellison ("Jellison") who was an employee of the oard. Jellison no longer
cr iii 1
works f§’ e1board in any capacity for over a month. ln fact she works in the town of Winchester, 1
@imectiopt fof1that`.Board of Education now.
LL?} 5 ·-·1‘i1
11 life Plaintiffs stated that Jellison lied and committed fraud when she illfully gave fraudulent 1
'TQLL
11@;ii(’)::I;II1EItIC¥I§I0 govcrrunental officials, which resulted in the false charge of edu ational neglect when she 1
__ Q ·. _ 1
. if 5,5* U; was asked at was in the Plaintiffs son’s record even though their son Ben had ot gone there in 3 years, 1
. I »
.‘ ·|` _
U 11. 1ithe records ere not even located there and Jellison was not given permissio to release or talk about
1 Q, 0
11 ,';1Ben’s recor . Jellison’s actions was intentional misconduct, and a willful and wanton act to ensure the
. 1 (U
gparents got unished due to the fact that there was hatred by Jellison again t the Plaintiffs for their
. ‘r‘11’
;§ S11 Qoppositiont Jellison’s appointment.
E rg Jelli on was specifically asked about Ben’s record and Jellison ex eded the scope of her
C1 "11 Q" 1
1 11 Qauthority an spoke about the Plaintiffs son’s educational needs and any special needs which was totally
Q 1
8 _ incorrect an in opposition to the actual record. Those above her namely Super' tendent, Michael Wasta
cv Q 1 1
.. E]; approved th home schooling and the Plaintiffs filled out all the appropriate p erwork. Andrew Lees,
CO :
0
*5 g head of Spe ial Education stated along with Wasta that Ben had no special needs yet Jellison told 1
sa
aiu 91 governrnen officials that Ben was special needs and should be in school. CF officials took what 1
1
1 1
...,_ . _ _. . _ __ . .. . . wl
was ez, ,; an =·.===-uy as- -» M m.; . ’ "‘ **1-- m·—-— —·—- —>..--