RETURN DATE: MAY 30, 2017 : SUPERIOR COURT

JOHN DOE : J.D. OF HARTFORD

VS. : AT HARTFORD

BRUCE BEMER and WILLIAM TREFZGER : APRIL 18, 2017

COMPLAINT
COUNT ONE: JOHN DOE v. BRUCE BEMER AND WILLIAM TREFZGER (Violation of
General Statutes 42-110a et seq.)
Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851

1. At all times mentioned herein, the plaintiff (JOHN DOE) was a minor and a
77 Lexington Street New Britain, Connecticut 06052

citizen of Connecticut.
LAW OFFICE OF KEVIN C. FERRY, LLC

2. The defendants are individuals who engaged in a continuous course of

depraved and corrupt business activity over many years, targeting mentally

disabled individuals for sexual exploitation, and willingly engaged in a

conspiracy to sexually abuse and traffic individuals, including plaintiff,

throughout the State of Connecticut, for financial gain and/or sexual

gratification in lieu of or in addition to financial gain.

3. On various dates, as set forth in the warrant affidavits, attached thereto as

Exhibits 1, 2, and 3, and incorporated herein, the defendants engaged in a

pattern of illegal and prohibited racketeering activity for purulent sexual

purposes in violation of the Connecticut Corrupt Organizations and

Racketeering Activity Act (CORA) (General Statutes 53-393 et seq.). Upon

information and belief, the defendants, or members of their racketeering

1
 conspiracy, knowingly received proceeds from sexual racketeering and

invested those proceeds in the establishment or operation of illicit enterprises

or in real or personal property.

4. As set forth above, the defendants, in violation of CORA, engaged in

racketeering activity, including committing, attempting to commit, conspiring to

commit, or intentionally aiding, soliciting, coercing, or intimidating the plaintiff

Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851

and others to commit extortion, drug offenses, assault, prostitution, including a

77 Lexington Street New Britain, Connecticut 06052

violation of General Statutes 53a-83(c)(2)(A) and/or coercion in violation of

LAW OFFICE OF KEVIN C. FERRY, LLC

General Statutes 53-394(a).

5. As set forth above, the defendants, in violation of CORA, engaged in a pattern

of racketeering activity including engaging in at least two incidents of

racketeering activity that (1) have the same or similar purposes, results,

participants, victims, or methods of commission or otherwise are interrelated by

distinguished characteristics; and (2) are not isolated incidents, all in violation

of General Statutes 42-110a et seq.

6. At all times mentioned herein, the defendants, or members of their

racketeering conspiracy, were engaged in the conduct of a trade or commerce

as defined in the Connecticut Unfair Trade Practices Act (CUPTA), General

Statutes 42-110a et seq.

2
 7. The acts of the defendants, or members of their racketeering conspiracy, as

set forth above, were oppressive, immoral, unscrupulous and in violation of

public policy, including that set forth in CORA and General Statutes 53a-

83(c)(2)(A), amounting to an unfair trade practice in violation of CUTPA,

General Statutes 42-110b et seq.

8. These despicable acts of defendants, or members of their racketeering

Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851

conspiracy, have resulted in ascertainable loss to the plaintiff, including bodily

77 Lexington Street New Britain, Connecticut 06052

invasion, sexual abuse, drug provision and addiction and exploitation of his
LAW OFFICE OF KEVIN C. FERRY, LLC

pre-existing mental and emotional disabilities that left him susceptible and as a

target of the defendants perverse criminal racketeering scheme.

COUNT TWO: JOHN DOE v. BRUCE BEMER-- (ASSAULT AND BATTERY)

1-8. At all times relevant, paragraphs 1-8 of Count Once are incorporated herein.

9. During the various times during the plaintiffs minority, defendant invited and

lured plaintiff to his office at Bemer Petroleum Corporation, located at 210

Commerce Street, Glastonbury, CT 06033 approximately 6-12 times, and

engaged in a pattern of inappropriate contact with and touching him for the

purpose of sexual gratification.

10. The injuries set forth by the plaintiff were the proximate result of the foregoing

assault and battery committed by the defendant, BRUCE BEMER, in one or

more of the following ways:

3
 a. In that defendant BRUCE BEMER engaged in sexual activities

with the plaintiff, who due to age and emotional impairments was

unable to protect himself and unable to consent to such sexual

activities;

b. In that defendant, BRUCE BEMER engaged in sexual activities

with the plaintiff knowing that he was a minor and had emotional
Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851

impairments to the extent he was unable to understand and

77 Lexington Street New Britain, Connecticut 06052

appreciate the risks associated with sexual activities, unable to

LAW OFFICE OF KEVIN C. FERRY, LLC

protect himself from the defendants, BRUCE BEMER, advances

and unable to consent to sexual activities with defendant;

c. In that defendant, BRUCE BEMER engaged in sexual activities

with plaintiff using intimidation threats and/or blackmail;

d. In that defendant, BRUCE BEMER sought out minors, the

plaintiff, in particular for the purpose of engaging in sexual acts;

e. In that defendant, BRUCE BEMER sought out minors, the

plaintiff in particular, for the purpose of engaging in sexual acts;

f. In that the defendant, BRUCE BEMER, elicited minors, the

plaintiff in particular, for the purpose of engaging in sexual acts;

g. In that defendant, BRUCE BEMER, exposed children, plaintiff in

particular, to pornographic videos, while engaging in sexual acts

with minors, plaintiff in particular;

4
 11. As a result of the aforesaid assault and battery by defendant, BRUCE

BEMER, the plaintiff suffered, and continues to suffer, injuries of a

serious nature, including but not limited to, physical injuries, emotional

distress, shock, terror, recurrent and intrusive recollections of the abuse,

anger, anxiety, post-traumatic stress disorder, depression, low self-

esteem, frustration and fear as well as psychological and psychiatric

Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851

disorders.
77 Lexington Street New Britain, Connecticut 06052

12. All or some of the plaintiffs aforementioned injuries are or may be

LAW OFFICE OF KEVIN C. FERRY, LLC

permanent in nature, or, if unresolved, impose the risk of serious mental

illness.

13. As a result of the aforementioned assault and battery by defendant,

BRUCE BEMER, the plaintiff has also suffered a loss of the full

enjoyment of lifes activities.

14. These violations were substantial factors in causing injuries to plaintiff

as set forth in this complaint.

15. As a result of this defendants assault and battery, plaintiff suffered

severe physical and emotional trauma, depression, and pain and

suffering. Many of these injuries are or may be permanent.

16. As a further consequence of the conduct of this defendant, plaintiff will

incur expenses for medical care, psychiatric care, and/or counseling.

5
 COUNT THREE: JOHN DOE v. BRUCE BEMER; RECKLESS AND WANTON
CONDUCT AGAINST BRUCE BEMER

1-8. At all relevant times herein, paragraphs 1-8 of Count One are

incorporated herein.

9-16. At all relevant times herein, paragraphs 9-16 of Count Two are

incorporated herein.

17. By taking a minor child with emotional impairments to his office at

Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851
77 Lexington Street New Britain, Connecticut 06052

Bemer Petroleum Corporation, where plaintiff could not be supervised

by any adult with authority and enforcing the safety and wellbeing of the
LAW OFFICE OF KEVIN C. FERRY, LLC

child, and by engaging him in sexual activity, defendant BRUCE

BEMER, engaged in conduct that was in reckless and wanton disregard

of plaintiffs rights.

18. Defendant BRUCE BEMER, knew or should have known that engaging

in sexual activity with a minor child would have serious emotional and

physical trauma.

19. As a result of the aforementioned wanton and reckless conduct by

defendant BRUCE BEMER, the plaintiff suffered, and continues to

suffer, injuries of a serious nature, including but not limited to, physical

injuries, emotional distress, shock, terror, recurrent and intrusive

recollections of the abuse, anger, anxiety, post-traumatic stress

6
 disorder, depression, low self-esteem, frustration and fear as well as

psychological and psychiatric disorders.

20. All or some of the plaintiffs aforementioned injuries are or may be

permanent in nature, or, if unresolved, impose the risk of serious mental

illness.

21. As a result of the aforementioned wanton and reckless conduct by

Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851

defendant, BRUCE BEMER, he has also suffered a loss of full

77 Lexington Street New Britain, Connecticut 06052

enjoyment of lifes activities.

LAW OFFICE OF KEVIN C. FERRY, LLC

22. These violations were substantial factors in causing injuries to the

plaintiff as set forth in this complaint.

23. As a result of this aforementioned wanton and reckless conduct, plaintiff

suffered severe physical and emotional trauma, depression and pain

and suffering. Many of these injuries are or may be permanent in nature.

24. As a further consequence of aforementioned wanton and reckless

conduct, the plaintiff will continue to suffer emotional trauma and anxiety

over this assault and will require counseling, therapy, medical care,

additional supervision and care.

25. As a further consequence of the conduct of this defendant, plaintiff has

incurred and will continue to incur expenses for hospital treatment,

medical care, psychiatric care and counseling.

7
 COUNT FOUR: JOHN DOE v. BRUCE BEMER; INTENTIONAL INFLICTION OF
EMOTIONAL DISTRESS AGAINST BRUCE BEMER

1-8. At all relevant times herein, paragraphs 1-8 are hereby incorporated

herein and made paragraphs 1-8 of Count Four.

9-16. At all relevant times herein, paragraphs 9-16 are hereby incorporated

herein and made paragraphs 9-16 of Count Four.

Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851

17. Defendant, Bruce Bemer took plaintiff, minor child at the time, to his
77 Lexington Street New Britain, Connecticut 06052

office at Bemer Petroleum Corporation approximately 6-12 times, and

LAW OFFICE OF KEVIN C. FERRY, LLC

engaged in sexual conduct with the minor child, exposing said minor

child to pornographic material, forcing plaintiff to take money, and

threatened plaintiff to not tell anyone about the sexual encounters or he

would blackmail, expose, and humiliate plaintiff.

18. By taking plaintiff, a minor child with emotional impairments, to

defendants office at Bemer Petroleum Corporation, where plaintiff could

not be supervised by any adult with authority or an adult enforcing the

safety and wellbeing of the child, and by engaging the plaintiff-minor

child in sexual activity and monetary exchanges, defendant BRUCE

BEMER, engaged in conduct that:

a. intended to inflict emotional distress upon plaintiff or should

have known that emotional distress was a likely result of

defendants conduct;

8
 b. was extreme and outrageous;

c. was the cause of plaintiffs distress; and

d. the emotional distress caused by plaintiff was severe.

19. As a result of the aforementioned intentional infliction of emotional

distress by defendant BRUCE BEMER, the plaintiff suffered, and

continues to suffer, injuries of a serious nature, including but not limited

Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851

to, physical injuries, emotional distress, shock, terror, recurrent and

77 Lexington Street New Britain, Connecticut 06052

intrusive recollections of the abuse, anger, anxiety, post-traumatic stress

LAW OFFICE OF KEVIN C. FERRY, LLC

disorder, depression, low self-esteem, frustration and fear as well as

psychological and psychiatric disorders.

20. All or some of the plaintiffs aforementioned injuries are or may be

permanent in nature, or, if unresolved, impose the risk of serious mental

illness.

21. As a result of the aforementioned intentional infliction of emotional

distress by defendant, BRUCE BEMER, he has also suffered a loss of

full enjoyment of lifes activities.

22. These violations were substantial factors in causing the injuries to

plaintiff set forth in this complaint.

23. As a result of this aforementioned intentional infliction of emotional

distress, plaintiff suffered severe physical and emotional trauma,

9
 depression and pain and suffering. Many of these injuries are or may be

permanent in nature.

24. As a further consequence of aforementioned intentional infliction of

emotional distress, the plaintiff will continue to suffer emotional trauma

and anxiety over this assault and will require counseling, therapy,

medical care, additional supervision and care.

Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851

25. As a further consequence of the conduct of this defendant, plaintiff will

77 Lexington Street New Britain, Connecticut 06052

continue to incur expenses for hospital treatment, medical care,

LAW OFFICE OF KEVIN C. FERRY, LLC

psychiatric care and counseling.

10
 RETURN DATE: MAY 30, 2017 : SUPERIOR COURT

JOHN DOE : J.D. OF HARTFORD

VS. : AT HARTFORD

BRUCE BEMER and WILLIAM TREFZGER : APRIL 18, 2017

STATEMENT OF AMOUNT IN DEMAND

Phone (860) 827-0880 Fax (860) 827-9942 Juris No. 429851
77 Lexington Street New Britain, Connecticut 06052

WHEREFORE, the plaintiff seeks:

1. Punitive Damages pursuant to General Statutes 42-110a et seq;

LAW OFFICE OF KEVIN C. FERRY, LLC

2. Attorneys Fees and Costs pursuant to General Statutes 42-110a et seq;

3. Money Damages; and

4. Such other relief as the Court deems just and appropriate.

This matter is within the jurisdiction of this court.

The Applicant-Plaintiff

By: __________________
Kevin C. Ferry
Law Office of Kevin C. Ferry, LLC
77 Lexington Street
New Britain, CT 06052
(t)860-827-0880
(f) 860-827-9942

11