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Case 3:18-cv-01140-JCH Document 1 Filed 07/11/18 Page 1 of 17

UNITED STATES DISTRICT COURT


DISTRICT OF CONNECTICUT

CHARMANE D. THURMAND : CIVILACTION NO:


PLAINTIFF,
V. :

UNIVERSITY OF CONNECTICUT, :
SUSAN B. HERBST, MUN Y. CHOI,
KENT HOLSINGER, SCOTT JORDAN,
STEPANIE REITZ, BRUCE GELSTON,
KIMBERLY HILL, CAROL CARSON,
THOMAS K. JONES, MARK E. WASIELEWSKI,
DEFENDANTS : JULY 11, 2018.

COMPLAINT

I. NATURE OF ACTION

1. This is an action for racial discrimination and retaliation in violation of Title VII of

the Civil Rights Act, as amended, 42 U.S.C.§ 2000 et. set., the Civil Rights Act of

1991, the First and Fourteenth Amendments to the United States Constitution

pursuant to 42 U.S.C. § 1983 for retaliation for speech on a matter of public concern

and denial of equal protection, and the Connecticut Fair Employment Practices Act

C.G.S. § 46a-51 et seq., and related torts of defamation, false light invasion of privacy,

negligent and intentional infliction of emotional distress under the common law of the

State of Connecticut.

II. JURISDICTION AND VENUE

2. The Court has jurisdiction over the subject matter of this action pursuant to 42 U.S.C.

§ 2000e-5(f)(3) and 28 U.S.C. §§1331, 1343, and 1367.

3. Venue is proper within this judicial district pursuant to 28 U.S.C. §1391 because all

of the events or omissions giving rise to the claims occurred in the State of

Connecticut and this District.


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III. PARTIES

4. The Plaintiff, CHARMANE D. THURMAND (“Thurmand” or “plaintiff”), at all

times mentioned herein, was an African-American female graduate student at

UCONN and the Graduate Diversity Officer at the University of Connecticut

Graduate Center, Storrs, Connecticut and was a resident of the State of Connecticut.

5. The Defendant, University of Connecticut (“UCONN”), at all times mentioned herein,

was an educational institution, located in Storrs, Connecticut.

6. The Defendant, SUSAN B. HERBST (“Herbst”), at all times mentioned herein, was

the President of UCONN and a resident of the State of Connecticut.

7. The Defendant, MIN Y. CHOI (“Choi”), at all times mentioned herein, was the

Provost of UCONN and a resident of the State of Connecticut.

8. The Defendant, KENT HOLSINGER (“Holsinger”), at all times mentioned herein,

was the Dean of the Graduate School at UCONN and a resident of the State of

Connecticut.

9. The Defendant, SCOTT JORDAN (“Jordan”), at all times mentioned herein, was the

Chief Financial Officer at UCONN and a resident of the State of Connecticut.

10. The Defendant STEPHANI REITZ, (“Reitz”), at all times mentioned herein, was the

Spokeswoman at UCONN and a resident of the State of Connecticut.

11. The Defendant BRUCE GELSTON, (“Gelston”), at all times mentioned herein, was

the Office of Audit, Compliance & Ethics investigator at UCONN and a resident of

the State of Connecticut.

12. The Defendant KIMBERLEY HILL, (“HILL”), at all times mentioned herein, was

the Associate Director for Community Standards at UCONN and a resident of the

State of Connecticut.

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13. The Defendant, CAROL CARSON (“Carson”), at all times mentioned herein, was the

Executive Director of the State of Connecticut, Office of State Ethics and a resident

of the State of Connecticut.

14. The Defendant, THOMAS K. JONES (“Jones”), at all times mentioned herein, was

the Ethics Enforcement Officer, Office of State Ethics and a resident of the State of

Connecticut.

15. The Defendant, MARK E. WASIELEWSKI(“Wasielewski”), at all times mentioned

herein, was the Deputy Enforcement Officer of the State of Connecticut, Office of

State Ethics and resident of the State of Connecticut.

IV. FACTS APPLICABLE TO ALL CAUSES OF ACTION

16. This case involves systemic discrimination and unequal treatment based upon race,

retaliation for speech on a matter of public concern, emotional distress and

defamation.

17. Plaintiff was employed by UCONN on October 1, 2012 as the UCONN Graduate

School’s (“Graduate School”) Diversity Officer until her constructive discharge on

February 24, 2017.

18. Plaintiff’ was a conscientious, hard-working and successful employee for her entire

time at UCONN. Plaintiff received no negative performance evaluations during her

tenure at UCONN.

19. Plaintiff was a Ph.D. candidate at the Graduate School until she was expelled on May

19, 2017.

20. Plaintiff publicly criticized UCONN and the Graduate School regarding

discriminatory practices and malfeasance, that included lack of standards and policies

regarding the awarding of diversity scholarships and grants, and discriminatory

policies and conduct toward minority students and candidates in the Graduate School.

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21. Plaintiff publicly spoke out about UCONN’s discriminatory conduct, including that

while the University publicly declared it valued diversity, it continued a racist policy

of treating individuals of color differently and adversely than their white counterparts.

22. As a result, plaintiff was subjected to harassment, and false criminal, administrative

and academic charges by defendants, who, jointly and severally, maintained them to

harm plaintiff’s employment and academic career.

23. Plaintiff was treated differently than other similarly situated individuals and retaliated

against by work place harassment, suspension and constructive termination.

24. On or about August 2016, without notice, Herbst, Choi, Jordan and Holsinger

instigated the original retaliatory investigation against plaintiff.

25. Herbst, Holsinger, Jordan and Reitz falsely and maliciously declared plaintiff

improperly obtained a fellowship for her husband, who was a graduate student at

UCONN and the Graduate School.

26. Plaintiff assisted the Graduate Schools’ Diversity Committee (“Committee”) which

was responsible for awarding various fellowships, scholarships and grants.

27. Herbst, Choi, Jordan and Holsinger, without cause, initiated and published false

charges of misconduct and thievery, based on plaintiff’s race and color.

28. Herbst, Choi, Jordan and Holsinger, acted in retaliation for plaintiff’s public criticism

of the Graduate Schools’ discriminatory and racist practices regarding scholarship and

grant programs.

29. Gelston, at the behest of the Herbst, Choi, Jordan, and Holsinger, conducted a biased,

racially and retaliatory employee investigation of the charges, purposely excluded

exculpatory evidence and witnesses, and made a false finding that plaintiff violated

provisions of the employee code, inter alia, that she deceived Holsinger and

illegitimately obtained a fellowship for her husband and thereby committed theft.

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30. Hill, at the behest of the Herbst, Choi, Jordan, and Holsinger conducted a biased,

racially and retaliatory student conduct investigation of these charges, purposely

excluded exculpatory evidence and witnesses and made a false finding that plaintiff

violated the provisions of the student code, stating that she deceived Holsinger and

illegitimately obtained a fellowship for her husband and thereby committed theft.

31. Gelston did not interview certain members of the Committee that would have negated

his findings and maliciously misrepresented witness statements to bolster his findings.

32. Hill ignored evidence, did not interview certain members of the Committee that would

have negated her findings, and maliciously misrepresented witness statements to

bolster her findings.

33. Herbst, Choi, Jordan and Holsinger, Gelston, Hill and Reitz falsely and maliciously

made material misstatements and omitted material facts from their reports.

34. Herbst, Choi, Jordan and Holsinger, instituted a false debt report against plaintiff with

the UCONN Bursars Office and later reported that false debt to collection and credit

agencies. UCONN has not obtained a judgment for this debt. Defendants falsely and

without basis reported this debt to credit agencies.

35. Defendants sham, racially and retaliatory motivated actions resulted in, inter alia, the
following discriminatory and adverse employment and academic actions:
a. Plaintiff was subjected to a hostile work environment from September 2016 to

February 24, 2017, at which time she was constructively discharged.

b. Plaintiff was subjected to a criminal investigation of these false charges by

UCONN Police.

c. Plaintiff was suspended from her position as Graduate Diversity Officer on

January 26, 2017.

d. Plaintiff constructive termination was, without any legitimate basis

characterized as in in bad standing.

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e. Plaintiff was denied attendance at academic events after she was wrongfully

terminated from her position, while still a student.

f. On May 19, 2017, plaintiff was academically expelled from the Graduate

School, destroying her Ph.D. candidacy.

g. Harm to plaintiff’s future career prospects and academic pursuits.

h. Loss of employment at Smith College.

36. UCONN has a pattern and practice of treating individuals of color differently than

their non-black cohorts.

37. Herbst, Choi, Jordan and Holsinger and Gelston instigated a false and malicious

criminal complaint to their own police department, UCONN Police that plaintiff

committed theft.

38. Herbst, Choi, Jordan and Holsinger, Gelston and Reitz then widely publicized the

false report and that plaintiff was under criminal investigation for theft.

39. Defendants published to the media Gelston’s confidential, false and deceitful

internal investigation report.

40. Defendants Herbst, Choi, Holsinger, Jordan and Gelston and Reitz published the

following false and defamatory statements:

A. On March 21, 2017, to the Hartford Courant:

[Plaintiff’s husband was ineligible because] he did not have the


required Ph.D., and because he was awarded it outside of the
standard application and review process.

B. On March 21, 2017, to the Hartford Courant:

Ms. Thurmand did not notify the Selection Committee that she
had included her (husband) as a Fellowship recipient. The
Selection Committee did not review and approve the Fellowship
award to her (husband) and it appears that Ms. Thurmand
deceived Dean (Kent) Holsinger in that regard.

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C. On March 21, 2017, to the Hartford Courant:

The evidence is clear that Ms. Thurmand's husband was not


nominated, selected or eligible for the Giolas-Harriott Fellowship.

D. On March 21, 2017, to the Hartford Courant:

We learned of the connection between the employee and the


fellowship recipient while doing standard due diligence in
reviewing our fellows in various programs throughout the
university.

E. On March 22, 2017,to The Daily Campus:

Thurmand gave her husband [], a graduate student, a 2016 –


2017 Giolas-Harriott Fellowship (GHF), which includes a
tuition waiver, financial aid support and a graduate
assistantship stipend totaling approximately $53,700,
according to a letter from UConn CFO Scott Jordan to the
state’s auditors and other documents provided by UConn
spokeswoman Stephanie Reitz.

F. On March 22, 2017, to The Daily Campus:

[Her husband] was not eligible for the scholarship, according


to a report by Compliance Investigation Officer Bruce
Gelston. This fellowship is reserved for doctoral students;
Evans is a masters student.

G. On March 22, 2017, to The Daily Campus:

Thurmand did not notify the selection committee for the


scholarships or her supervisor that she was including her
husband in a list of recipients, Gelston reported.

H. On March 22, 2017, to The Daily Campus:

“UConn Police are investigating the case, spokeswoman Reitz said.”

I. On March 22, 2017, to NBC Connecticut Troubleshooters television:

An employee at the University of Connecticut (UConn) is


accused of using her job to award her husband a fellowship
worth tens of thousands of dollars. The employee, Charmane D.
Thurmand … husband, … was awarded $53,700 fellowship
without even applying.

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J. On March 22, 2017, to NBC Connecticut Troubleshooters television:

According to school officials, [Thurmand’s husband] was not pursing a


doctorate degree at UConn and did not go through any of the normal
procedures required to be awarded the fellowship.” ‘ in addition,
auditors said she violated the school's nepotism policy, code of conduct
and code of ethics’ “Thurmand and [her husband] are under
investigation by UConn police.

https://www.nbcconnecticut.com/news/local/UConn-Employee-Accused-of-Awarding-Husband-
Fellowship-he-Didnt-Apply-For-416889353.html

41. The aforementioned reports and publications falsely and maliciously inferred that

plaintiff was a deceptive dishonest employee, a thief and criminal.

42. Other non-minority employees with similar allegations were not suspended or forced

out of their employment with their conduct negatively described.

43. Other non-minority students with similar situations were not expelled.
44. On or about March 2017, when defendants realized their criminal charges were

unavailing, UCONN, and Herbst, Choi, Jordan, Holsinger, Gelston, Hill and Reitz

colluded with the State of Connecticut, Office of Ethics to bring false and

discriminatorily motivated ethics charges against plaintiff.

45. On or about March 2017, Carson, Jones and Wasilewski of the Connecticut Office of

State Ethics instigated a retaliatory, racially motivated and baseless ethics complaint

against plaintiff (“Ethics Complaint”).

46. The Ethics Complaint was initiated to help of UCONN, Herbst, Choi, Jordan and

Holsinger, Gelston, Hill and Reitz’s discriminatory and retaliatory agenda.

47. The Ethics Complaint has been used by all defendants to harass, annoy, embarrass,

humiliate and harm plaintiff in further retaliation for her protected speech and

discrimination complaints.

48. Carson, Jones and Wasilewski have continued their meritless case despite their

knowledge of its racially discriminatory genesis, lack of cause.

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49. Carson, Jones and Wasilewski have abused their authority by issuing illegitimate and

defamatory subpoenas to plaintiff, academic institutions, financial institutions,

colleagues and employers, clearing disclosing that she is the subject of an ethics

investigation..

50. Plaintiff lost her position at Smith College after the college received false and

derogatory information from defendants.

51. UCONN destroyed plaintiff’s objective to obtain a doctoral degree.

52. Defendants were aware, refused to investigate and allowed this discrimination to

continue.

53. The defendants, during all times mentioned in this action, acted under color of law of

the Constitution and Statutes of the United States and State of Connecticut, the laws,

charter, ordinances, policies, rules, regulations, customs and usages of the State of

Connecticut.

54. The injuries to the plaintiff were the direct and proximate cause of the intentional

actions of the defendants.

55. As a consequence of the defendants actions the plaintiff suffered significant economic

harm, humiliation, pain, embarrassment, anxiety, stress, emotional mental upset, loss

of sleep, lost revenue, continued professional harm and attorney’s fees.

V. COUNT ONE- RACIAL DISCRIMINATION (TITLE VII)

56. Plaintiff realleges all paragraphs as set forth fully herein.

57. This lawsuit is brought under 42 U.S.C. § 2000 et seq. (Title VII), which prohibits

employers from discriminating “against any individual with respect to her

compensation, terms, conditions, or privileges of employment, because of such

individual’s race, color, religion, sex or national origin.” See e.g. 42 U.S.C. § 2000e-

2(a).

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58. UCONN discriminated against Thurmand based upon her race. As a proximate cause

of this discrimination, plaintiff lost wages, promotion and other employment

opportunities.

59. Herbst, Choi, Holsinger and Jordan, supervisors for UCONN, and Reitz, Hill and

Gelston as their subordinates, conspired to build a pretextual case to terminate

plaintiff’s employment and academic standing by manufacturing false and damaging

allegations, filing false and damaging reports, creating a hostile and discriminatorily

antagonistic work and school environment in order to force plaintiff to leave her work

position. When plaintiff did not leave, defendants expelled her from her doctoral

degree program.

60. UCONN exacted racial discrimination against Thurmand in violation of Title VII.

61. UCONN fostered a “hostile work environment” against Thurmand in violation of

Title VII.

62. UCONN terminated Thurmand in violation of Title VII.

63. Thurmand received a “Release of Jurisdiction” letter for her complaint against

UCONN from the Connecticut Commission on Human Rights and Opportunities

(“CHRO”) Docket Number 1740383 on May 22, 2018. (Attached as Exhibit 1).

64. Thurmand received a “Right to Sue” letter from the United States Equal Employment

Opportunity Commission (“EEOC”). Docket Number 16A201701180 on May 22,

2018. (Attached as Exhibit 2).

65. As a direct and proximate result of defendants hostile, discriminatory and retaliatory

treatment of her, plaintiff has suffered, and continues to suffer, adverse job

consequences, lost wages, lost academic advancement, economic damages, pain,

mental anguish, loss of enjoyment of life and damage to her reputation and career.

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VI. COUNT TWO –TITLE VII RETALIATION

66. Plaintiff realleges all paragraphs as set forth fully herein.

67. Defendants retaliated against Thurmand in violation of 42 U.S.C. § 2000e-3 [Section

704], which prohibits employers from retaliating against an employee “because such

individual has opposed any act or practice made unlawful by this chapter or because

such individual made a charge, testified, assisted, or participated in any manner in an

investigation, proceeding, or hearing, under this subchapter.”

68. Defendants’ adverse employment actions against plaintiff were in retaliation for her

opposing discrimination and violated her rights under Title VII.

69. The reason advanced by the defendants for their action against plaintiff was a pretext

for their retaliatory conduct.

70. As a direct and proximate result of defendants retaliatory treatment of her, plaintiff

suffered, and continues to suffer, adverse job consequences, lost academic

advancement, economic damages, pain, mental anguish, loss of enjoyment of life and

damage to her reputation and career.

VII. COUNT THREE—FOURTEENTH AMENDMENT EQUAL PROTECTION

71. Plaintiff realleges all paragraphs as set forth fully herein.

72. The Equal Protection Clause of the Fourteenth Amendment commands that no

government, “deprive to any person within its jurisdiction the equal protection of the

laws” and requires that the government treat all similarly situated people alike.

73. The defendants, by their conduct violated the Equal Protection rights guaranteed to

Thurmand by the Fourteenth Amendment to the United States Constitution.

74. Thurmand was part of a “protected class”, a distinct group of individuals, African-

American female, which UCONN categorically treated differently.

75. Thurmand was subjected to selective enforcement of discipline in that she was (1)

treated differently from other similarly situated individuals, and (2) that such

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differential treatment was based on impermissible consideration of her race and

intended to inhibit her exercise of her rights and inflicted with malice, bad faith and

intent to injure.

76. As a direct and proximate result of defendants’ denial of her equal protection under

the law the plaintiff has suffered, and continues to suffer, adverse job consequences,

including economic damages, pain, mental anguish, loss of enjoyment of life and

damage to her reputation and career.

VIII. COUNT FOUR- FIRST AMENDMENT RETALTIATION

77. Plaintiff realleges all paragraphs as set forth fully herein.

78. Plaintiff’s speech was protected by the First Amendment as it would be fairly

characterized as constituting speech on a matter of public concern.

79. The defendants, jointly and severally, operated to deny the plaintiff her rights to

protected speech pursuant to the First Amendment of the United States Constitution.

80. Plaintiffs speech concerning defendants’ discriminatory conduct and racist policies

was made based on her interest as a citizen to comment on matters of public concern

and did not conflict with expected interest of her employer in promoting the efficiency

of the public services UCONN performs through its employees.

81. The individual defendants, by their conduct, violated the Free Speech and Association

rights guaranteed to the Plaintiff by the First Amendment to the United States

Constitution, as secured by the Fourteenth Amendment to the United States

Constitution and the Constitution of the State of Connecticut, Article First, Section 4..

82. The individual defendants knew that their conduct was abusive and retaliatory, and

conspired to create a hostile work and academic environment to force plaintiff from

her position knowing that it would deny her procedural protections and rights

guaranteed under the aforementioned statutes, policies, laws and the Constitutions of

the United States and State of Connecticut.

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IX. COUNT FIVE--CONNECTICUT FAIR EMPLOYMENT PRACTICES ACT

83. Plaintiff realleges all paragraphs as set forth herein.

84. UCONN, by and through its agents and/or employees violated the Connecticut Fair

Employment Practices Act (“CTFEPA”), CGS § 46a-60(a)(1) and (4) and § 46a-81(c)

et seq. in one or more of the following ways:

a. In that defendant interfered with plaintiff’s privilege of employment on the basis

of plaintiff’s race and;

b. In that defendant discriminated against the plaintiff in such a way that it adversely

affected her status as an employee;

c. In that defendant treated plaintiff adversely different from similarly situated

employees;

d. In that defendant significantly altered plaintiff’s employment conditions; and

e. In that defendant intentionally discriminated against the plaintiff.

f. In that defendant created a hostile work environment;

g. Defendants’ adverse employment actions against plaintiff were in retaliation for

her opposing discrimination which violated CGS § 46a-60(a)(4).

X. COUNT SIX –NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

85. Plaintiff realleges all paragraphs as set forth fully herein.

86. The acts and conduct of the defendants constitute negligent infliction of emotional

distress upon the plaintiff, for which the defendants are liable to the plaintiff at

common law.

87. The defendants should have realized that their conduct involved an unreasonable risk

of causing emotional distress, and that the emotional distress would result in illness

or bodily harm.

88. The defendants’ conduct caused the plaintiff severe emotional distress and caused the

plaintiff damages.

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XI. COUNT SEVEN –INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

89. Plaintiff realleges all paragraphs as set forth fully herein.

90. The acts and conduct of the defendants constitute intentional infliction of emotional

distress upon the plaintiff, for which the defendants are liable to the plaintiff at

common law.

91. Defendants intended to inflict emotional distress or knew that or should have known

that emotional distress was a likely result of their conduct.

92. The defendants’ conduct was extreme and outrageous.

93. The defendants’ conduct caused the plaintiff severe emotional distress and caused the

plaintiff damages.

XII. COUNT EIGHT- DEFMATION

94. Plaintiff realleges all paragraphs as set forth fully herein.

95. Defendants published the aforementioned defamatory statements to third parties.

96. The defamatory statements identified the plaintiff to third persons.

97. The defamatory statements harmed plaintiff’s reputation.

98. Defendants statements were slander per se as they charged plaintiff with

incompetency in office and dishonesty and inferred that she committed a crime,

entitling plaintiff to punitive and exemplary damages.

99. Plaintiff claims damages.

XIII. COUNT NINE- FALSE LIGHT INVASION OF PRIVACY

100. Plaintiff realleges all paragraphs as set forth fully herein.

101. Defendants placed plaintiff in the false light that she was a poor employee, engaging

in theft and crimes.

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102. Defendants publicly disclosed private information regarding plaintiff’s education

records that is protected by the Federal Education Rights and Privacy Act, 20 U.S.C.

§1232g (“FERPA).

103. Defendants acted with knowledge or reckless disregard to the falsity of the publication

and the false light in which it placed the plaintiff.

104. Plaintiff claims damages.

XIV. COUNT TEN- SLANDER OF CREDIT

105. Plaintiff realleges all paragraphs as set forth fully herein.

106. Defendants maliciously made false statements and reports to credit agencies of

plaintiff’s nonpayment of debts that resulted in harm to plaintiff’s reputation and

credit.

107. Plaintiff claims damages.

XV. COUNT ELEVEN- VICARIOUS LIABILITY

108. Plaintiff realleges all paragraphs as set forth fully herein.

109. The acts or omissions were by the employees, agents and servants of UCONN. These

individuals acted in the course and scope of their employment at the time of the acts

that constitute the claims in this lawsuit.

110. UCONN had a duty to ensure its employees were properly trained and aware of the

rules and regulations governing the workplace.

111. These employees had a duty to students to maintain the confidentiality of information

and records.

112. UCONN failed to exercise ordinary care in supervising the individual defendants in

their roles, and failed to prevent foreseeable misconduct causing harm to plaintiff.

113. UCONN is liable for the acts and omission of its employees.

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114. UCONN is responsible for the conduct of the individual defendants pursuant to the

doctrine of respondeat superior as a result of the master-servant relationship which

existed at the time of the aforementioned acts alleged in her complaint.

XVI. ACTUAL DAMAGES

115. Plaintiff pleads for pre and post judgment interest at the maximum allowable rate.

Plaintiff is entitled to actual damages, back pay, front pay, out of pocket expenses,

loss of benefits, consequential damages, damage to her reputation past and future, lost

and future wages, lost and future wage-earning capacity.

WHEREFORE, THE PLAINTIFF CLAIMS:

1. Compensatory money damages from each defendant;

2. Injunctive relief prohibiting the State of Connecticut Ethics Office from

continuing their illegitimate, discriminatory and retaliatory investigation;

3. A declaratory judgment against defendants; that UCONN publicly

acknowledge that it was not able to substantiate any malfeasance by

plaintiff;

4. Punitive damages from each defendant;

5. Any and all nominal damages from each defendant;

6. Attorney’s fees pursuant to Title VII and 42 U.S.C. §§ 1983 and 1988.

7. Common law attorney’s fees;

8. All costs associated with the bringing of her lawsuit;

9. Such other relief as in equity may pertain.

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CLAIM FOR A JURY TRIAL

The plaintiff requests a trial by jury for all issues in this case.

PLAINTIFF,

CHARMANE THURMAND

BY: /S/ James S. Brewer. (ct 07019)


____________________________
James S. Brewer
67 Russ Street
Hartford, CT 06106
860-217-0652
jbreweratty@gmail.com

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