Maureen Casey vs. WESD: Complaint

Judy Danelle Snyder, ass # 732834
E-mail: judy@jdsnyder.com
LAW OFFICES OF JUDY SNYDER
1000 S.W. Broadway, Suite 2400
Portland, OR 97205
Telephone: (503) 228-5027
Facsimile: (503) 241-2249
Of Attorneys for Plaintiff
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
EUGENE DIVISION
MAUREEN T. CASEY,
Plaintiff,
v.
WILLAMETTE EDUCATION SERVICE
DISTRICT, a political subdivision of the State of
Oregon and a public body corporate, DAVE
NOVOTNEY, individually and as an employee of
WESD, and JACK W. STOOPS, individually and
as an agent of WESD,
Defendants.
Case No.
COMPLAINT
42 U.S.C. 1983 - VIOLATION OF
PROCEDURAL DUE PROCESS
(LIBERTY INTEREST); 42 U.S.C.
1983 - VIOLATION OF SUBSTANTIVE
DUE PROCESS; BREACH OF
CONTRACT; DEFAMATION;
INTENTIONAL INTERFERENCE
WITH ECONOMIC RELATIONS
PRELIMINARY STATEMENT
1. This is an action for declaratory, injunctive, and monetary relief, including punitive damages
and attorneys' fees and costs, to redress defendants' violations of plaintiff's federally protected rights and
state common law claims.
JURISDICTION
2. Plaintiff's first claim arises under 42 U.S.C. 1983. The court has jurisdiction of the action
under 28 U.S.C. 1331, federal question jurisdiction, and 28 U.S.C. 1343, civil rights jurisdiction. This
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1000 S.W. BROADWAY, SUITE 2400
PORTLAND, OREGON 97205
(503) 228-5027
FAX (503) 241-2249
Case 6:10-cv-06333-TC Document 1 Filed 10/12/10 Page 1 of 16 Page ID#: 1
FILED: 9/12/10
10-6333-TC
600005867
court has supplemental jurisdiction of plaintiff's state common law claims under 28 U.S.C. 1367.
PARTIES
3. Plaintiff Maureen T. Casey ("Dr. Casey") is a resident of the State of Oregon. From July
1, 2004 through October 20, 2009, Dr. Casey was employed as the Superintendent of the Willamette
Education Service District.
4. Defendant Willamette Education Service District ("WESD") is a political subdivision of the
State of Oregon and a public body corporate created under ORS 334.010. WESD provides programs and
services to 21 school districts in Marion, Polk and Yamhill counties. At all material times, WESD was
governed by Jack Stoops, Ed Dodson, Mark Trumbo, Dora Velasco, Phil Freg, Larry Trott, Frank W.
Pender, Jr., Michael Eichman, and Ruth Hewitt, a WESD Board of Directors, each representing a specific
geographic zone or area of emphasis within WESD.
5. Defendant Dave Novotney ("Novotney") is an employee of WESD who served as either the
Deputy Superintendent, or Acting Superintendent of WESD.
6. Defendant Jack W. Stoops ("Stoops") was the Chair of the WESD Board of Directors.
GENERAL ALLEGATIONS
7. As Superintendent, Dr. Casey reported to the Board of Directors ofWESD. Dr. Casey was
responsible to supervise and administer the services and educational programs of WESD under the
general supervision of the WESD School Board. Dr. Casey directly supervised numerous directors of the
WESD programs, including but not limited to, Ann O'Connell ("O'Connell"), the former Director of Special
Programs for WESD, and Kathy Campbell ("Campbell"), the former Director of Fiscal Services.
8. Dr. Casey was employed by WESD under a written Contract which did not expire until June
30, 2010, and which provided limitations on WESD's right to earlier termination of that Contract, including
granting Dr. Casey the right to a due process hearing before the Board prior to the occurrence of any
purported act of termination. The Contract 'further provided, in part, that "[t]he members of the Board,
individually and collectively, shall promptly refer all criticism, complaints and suggestions called to its
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attention to the Superintendent for analysis and recommendation."
9. Novotney had advised Dr. Casey and others that he wanted Dr. Casey's position as
Superintendent of WESD. Without Dr. Casey's knowledge, in October of 2008, Novotney began to meet
with Campbell. Thereafter, Novotney and Campbell met with Stoops to advise him of Campbell's alleged
concerns about Dr. Casey. Thereafter, Stoops met with both Campbell and O'Connell, in O'Connell's
home to discuss their alleged concerns about Dr. Casey and to offer his support. Dr. Casey was unaware
of these meetings and she was not informed of the alleged concerns of either Campbell, or O'Connell,
which denied Dr. Casey the opportunity to address Campbell and O'Connor's concerns in a timely and
appropriate manner.
10. Stoops retained James Buck ("Buck") to gather information that he intendeq to use to alter
Dr. Casey's annual performance evaluation, which had already been completed by Board members in
written form but not yet adopted at a full Board meeting, and to investigate the alleged complaints of
Campbell and O'Connell. Buck is not licensed to be an investigator. Stoops hired Buck before obtaining
Board approval and prior to the submission of any written complaint by either Campbell or O'Connell. He
did so pursuant to a plan developed with Novotney. Stoops and Novotney violated WESD policy and
Administrative Rule by taking action before a written complaint had been filed. Stoops and Novotney did
not disclose to the other members of the WESD Board that complaints had been made, or that Buck had
been hired, nor did they advise Dr. Casey of the allegations of either Campbell, or O'Connell. Thereafter,
Stoops and Novotney continued to have private conversations with Campbell and O'Connell.
11. On April 21 , 2009, O'Connell filed an internal complaint against Dr. Casey with the WESD,
which raised false allegations about Dr. Casey. On April 23, 2009, Campbell filed an internal complaint
against Dr. Casey with the WESD, which raised additional false allegations about Dr. Casey.
12. Stoops and Novotney failed to disclose to the WESD Board the performance deficiencies
of Campbell and O'Connell, of which they were aware, so as to ensure that Dr. Casey would be blamed
for Campbell's and O'Connell's shortcomings and ultimately be terminated. They also failed to advise the
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Board that they had been meeting secretly with Campbell and O'Connell.
13. It was not until April 27,2009, that Dr. Casey was advised of either the Campbell, or the
O'Connell complaints. At this time, Novotney took over all supervisory responsibilities for Campbell and
O'Connell. Stoops, Novotney and Campbell continued their private conversations. Stoops and Novotney
shared results of the Buck investigations prior to their completion with Campbell, O'Connor and others.
14. On June 13, 2009, Buck released to the WESD Board his reports of his investigation of the
Campbell and O'Connell complaints. Shortly thereafter on June 18, 2009, Campbell's attorney sent a Tort
Claims Notice to WESD. Stoops then emailed Campbell's Tort Claims Notice to all 21 district
Superintendents and it was posted on the WESD website. Stoops also personally called some of the
Superintendents in WESD's regions to discuss with them the complaints against Dr. Casey. These were
actions which have never previously, and have not subsequently, been taken against any WESD
administrator, or in response to any other Tort Claims Notice.
15. Buck's reports were critical of Dr. Casey, but the reports were not reliable as there were
numerous deficiencies, omissions and inaccuracies in Buck's investigations and reports.
15.1 The deficiencies in Buck's investigation and report on the O'Connell complaint
included the following:
A. Information from all interviewees was not included. Several key points
made by individuals interviewed, whose information was excluded, would
have contradicted statements in the report. As a result, a false impression
of the body of information available was created, rendering the investigation
conclusions and the report neither complete or accurate;
B. Many of the examples provided in the report were based on individual
conflicting perceptions that could not be corroborated;
C. Additional information was not included in the report regarding concerns
about O'Connell reported by several WESD Special Programs
administrators, which had resulted in Dr. Casey providing negative feedback
to O'Connell;
D. Concerns regarding O'Connell's performance shared by Novotney with Dr.
Casey were omitted from the report;
E. Several district and WESD administrators had reported specific concerns
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and issues relative to O'Connell's management, leadership and
communication to Novotney. Both Buck and Novotney were aware of this
information, but it was excluded from the report;
F. The report falsely attributed Buck's conclusions to be based on a "majority
of those in high ranking positions";
G. Information from ten administrators stating they had never experienced or
witnessed incidents of bullying by Dr. Casey was omitted from the report;
and
H. Buck included biased recommendations, not just findings and conclusions.
15.2 The deficiencies in Buck's investigation and report on the Campbell complaint
included the following:
A. Failure to interview key witnesses including the former Director of Fiscal
Services;
B. Buck's report redefined "bullying" and "intimidation" beyond agency policy
definition. Campbell did not use these terms in her original complaint;
C. Buck's report contained biased comments from the investigator;
D. Information from ten administrators stating they had never experienced or
witnessed incidents of bullying by Dr. Casey was omitted from the report;
E. Buck included biased recommendations, not just findings and conclusions;
F. Buck added his personal opinion regarding budgeting and audit issues.
Buck specifically stated he had not been hired to investigate fiscal
allegations, that another firm had been hired to investigate fiscal allegations,
yet Buck expressed his personal concerns and interpretations regarding
fiscal issues in his report; and
G. Buck judgmentally criticized Dr. Casey's response in his report.
16. On June 25, 2009, Dr. Casey was placed on administrative leave by the WESD Board as
a result of the information contained in Buck's reports. Thereafter, Stoops prepared a letter on behalf of
WESD, which was publically disseminated, and which described the formal investigation being conducted
by AKT, an accounting firm, of the WESD financials and the alleged conduct of Dr. Casey, and which
reported that she had been put on paid leave as of June, 2009.
17. At a meeting of the Superintendents of the District on September 17, 2009, Novotney
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reported the results of the reports by AKT and Buck. He further told the Superintendents that at the
September 22, 2009, WESD Board meeting, the Board would go into Executive Session to discuss
whether Dr. Casey would be brought back to work, brought back with a reprimand, or dismissed. Novotney
further reported that WESD would have a statement ready for the press, that they were working with a
Public Relations firm in Portland, and that if the Board were to terminate Dr. Casey's employment, her
hearing would be on October 5, 2009. Novotney also reported to the Superintendents that Campbell would
be returning to work at WESD on September 21, and that WESD did not need to worry about Dr. Casey
coming back.
18. On September 22, 2009, the WESD Board accepted the Findings of Fact and Conclusions
made by Buck before Dr. Casey had the opportunity to a due process hearing to present evidence or
witnesses before an impartial tribunal, or to cross-examine adverse witnesses. On that date, WESD
issued a Press Release entitled "Willamette ESD Board finds substantial evidence to support allegations:"
In that Press Release, the WESD Board and Stoops made false statements regarding the alleged
evidence and reported that the investigation supported allegations of fiscal improprieties and violations of
personnel policies by Dr. Casey.
19. On September 22, 2009, Stoops, as WESD Board Chair, issued a separate written
statement in which he reported that the "investigations were conducted after employees alleged that
Superintendent Maureen Casey violated Board personnel policies, and after alleged fiscal improprieties
**** Tonight we are moving forward. We have accepted the findings of these reports. The Board has
directed our attorneys to inform Dr. Casey that we have substantial evidence to uphold most portions of
the employee complaints *** The Board plans to reconvene [on September 25] to consider the legal
analysis and take action..... " Stoops further pledged to make the reports on Dr. Casey public as soon as
possible.
20. On Septerrlber 25, 2009, WESD issued a second Press Release entitled "Willamette ESD
Board gives notice of intent to terminate the employment contract for Superintendent Casey." In that Press
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Release, Stoops, as WESD Board Chair, was quoted as saying "Today's decision provides some closure
on a difficult and lengthy process... It is the Board's hope that it marks a milestone that will allow the
agency to continue to rebuild trust with its partners... " The Press Release also announced that then
Deputy Superintendent Novotney would continue to discharge the duties of Superintendent and that the
Board would determine its options for a new Superintendent.
21. By letter dated September 25, 2009, the WESD Board notified Dr. Casey of the unanimous
decision of the Board to recommend the termination of her employment contract for cause. That letter set
forth a series of findings of the financial investigators "which the Board accepted" to support the notice of
termination of Dr. Casey's employment and stated that the Board was unanimous in giving Dr. Casey
notice of its intention to recommend the termination of Dr. Casey's employment contract for cause.
Because of the Press Releases and the written and oral statements made by the Board and by Stoops,
Dr. Casey concluded that her termination decision had already been made by the Board, despite her right
under her contract of employment to have a due process hearing before an impartial fact finder prior to
the occurrence of any purported act of termination.
22. In September of 2009, prior to the Board's vote to terminate Dr. Casey's Contract, auditors
from the Pauly Rogers accounting firm informed WESD attorney Mark Comstock, Stoops, Novotney and
Board Vice-Chair Ed Dodson of their concerns about Campbell's competency, deficiencies in her skill set
to perform her job and her violation of state law and Board policy when she transferred funds without
authorization. These concerns were not shared with other WESD Board members prior to the decision
to terminate Dr. Casey's employment.
23. At a special meeting with the North Santiam School District Board of Directors and
Superintendent on October 8, 2009, Novotney and Stoops falsely stated that WESD had used component
districts' resolution dollars to support a WESD service known as Pentamation Business and Student
Software and that those funds would be returned to the member districts.
24. WESD posted and retained on its public website a series of documents, including an Agreed
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Upon Procedure Report prepared by AKT, LLP ("AKT"), which disclosed improvements needed in
communications and internal controls at WESD, but which have been misrepresented by WESD as support
for the false accusations of alleged financial improprieties by Dr. Casey. In Dr. Casey's role as
Superintendent, all of her decisions were made in the best interests of the WESD using the information,
advice and expertise of staff who provided a level of detailed information and day-to-day management of
the program fiscal budgets.
25. WESD also posted and retained on its website documents entitled Findings of Fact and
Conclusions Concerning Complaint of Kathy Campbell and Findings of Fact and Conclusions Concerning
Complaint of Ann O'Connell. These documents contain information which are private personnel matters
pertaining to Dr. Casey and which should not have been disclosed to the public. WESD also posted on
its website a copy of the October 20, 2009 written Motion to Terminate Dr. Casey's employment and the
October 21, 2009 letter of termination of Dr. Casey's Contract of employment, each of which repeated
many of the false statements described above.
26. On October 20, 2009, WESD issued another Press Release which announced the
termination of Dr. Casey's employment. The Press Release mischaracterized AKT as a "forensic audit
firm," despite the fact that AKT had provided only an Agreed Upon Procedures Report regarding the
matters in issue, a process which is less thorough than a forensic audit. In that Press Release, WESD
again reported the termination of Dr. Casey's employment and made false allegations of fiscal impropriety
by Dr. Casey. WESD failed to disclose that during the time period reviewed by AKT while preparing the
Agreed Upon Procedures Report, WESD had engaged two outside auditing firms to review WESD
practices without either firm noting any significant issues.
27. At the October 22,2009 Superintendents meeting, Novotney falsely reported that WESD
may not have spent the required 90% of state school funds and local taxes on District services; that District
funds may have been used to pay for purchase and development of the Pentamation Business and
Student Software program; and that $1.3 million plus interest, for a total of approximately $1.7 million,
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would be returned to the Districts by WESD, because these District funds were inappropriately kept by
Dr. Casey. These statements were not dispelled until late June, 2010, when the final AKT report
exonerated Dr. Casey from these false accusations.
28. On December 2, 2009, Dr. Casey sent written Tort Claims Notice to WESD as a result of
the previously described events.
29. On November 19,2009, Campbell's attorney sent a revised Tort Claims Notice to the WESD
in which numerous allegations were made by Campbell of intimidation and inappropriate fiscal practices
by Novotney. At the December 8, 2009, WESD Board meeting, Stoops reported that WESD would not
pursue an investigation regarding Campbell's allegations against Novotney, asserting that "we have all the
faith in the world in Dave and know he would not do this." Stoops did not email the revised tort claim
accusations made against Novotney to all Superintendents; he did not make phone calls to
Superintendents explaining the accusations; nor was the revised tort claim notice posted on the WESD
web site for public review. There was no consideration by the WESD Board of the distinction between the
manner in which Campbell's complaints about Dr. Casey were communicated and investigated and those
against Novotney were not.
30. On April 21, 2010, in his individual capacity and not as WESD Board Chair, Stoops
appeared at a WESD Zone 3 Candidates Forum while he was campaigning for re-election to the WESD
Board. At that time, he provided the individuals who attended the forum a hand-out which, in part, falsely
reported that "the former administration of WESD created a very improper, difficult, and costly situation
for the agency. Legal staff and I actually started this comprehensive investigation on February 18, 2009
and I believe that we have done the right things to correct the problems, and begin to restore this agency
to its former level of respect ***** we discovered that when we began this process certain individuals in our
agency ran two different sets of books - deceiving the board in its operations." He further stated that Dr.
Casey "ran two different sets of books" and "that she lied to him." He 'further stated that "I was not involved
in the hiring of our former superintendent, but I have been very involved in correcting the inappropriate
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management decisions she made." Stoops then advocated for hiring "a superintendent who is grounded
in ethics, integrity, and honesty."
31. In June of 2010, the AKT final report was released which documented that WESD did not
owe any funds to the component Districts, despite the prior representations of Novotney that $1.7 million
was owed; that the requirement for 90% of State School funds and local taxes to be spent on member
districts was not only met over the preceding 5 years, but exceeded; and that District funds were not used
to purchase Pentamation software.
FIRST CLAIM FOR RELIEF
(Against All Defendants)
(42 U.S.C. 1983 - Violation of Procedural Due Process - Liberty Interest)
32. Plaintiff realleges and incorporates paragraphs 1 through 31 above.
33. Plaintiff has a liberty interest in her reputation for honesty, fairness and competence.
34. The information published by defendants was false and misleading as described in
paragraphs 14-20 and 23-27 of this Complaint. Further, the information that was released, and the
relevant information which was withheld when the partial information was publically disclosed was intended
by defendants solely for the purpose of falsely calling into question Dr. Casey's integrity, professionalism,
and reputation for honesty, fairness and competence.
35. Defendants did not provide plaintiff with any pre- or post-termination right to a hearing
before an impartial decision maker, with the right to present evidence and cross-examine witnesses in
connection with the false and misleading information and allegations described in paragraphs 7 though
31 above.
36. As a result of plaintiff's deprivation of the right to a hearing before an impartial decision
maker, plaintiff has been unable to find other employment.
37. As a direct result of the termination of Dr. Casey's employment, she has sustained
economic damages from October 21, 2009, until her expected retirement date for her lost wages and
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benefits, including contributions to her TSA and PERS accounts in an amount to be determined, but
estimated to be in the sum of $600,000, plus prejudgment interest in an amount to be determined at trial.
38. As a 'further and direct result of the termination of Dr. Casey's employment, she has
susta.ined compensatory damages for humiliation and emotional distress and damage to her personal and
professional reputation in an amount to be determined, but estimated to be in the sum of $800,000.
39. As a further and direct result of the false statements made about Dr. Casey by Novotney
and Stoops, Dr. Casey has sustained additional compensatory damages for humiliation and emotional
distress and damage to her personal and professional reputation in an amount to be determined, but
estimated to be in the sum of an additional $800,000.
40. Pursuant to 42 U.S.C. 1988, Dr. Casey is entitled to an award of her reasonable attorney's
fees and costs, including expert witness fees.
41. The comments and conduct of defendants Novotney and Stoops showed reckless or a
callous indifference to Dr. Casey's constitutional rights. Dr. Casey is entitled to an award of punitive
damages against these defendants.
SECOND CLAIM FOR RELIEF
(Against All Defendants)
(42 U.S.C. 1983 - Violation of Substantive Due Process)
42. Plaintiff realleges and incorporates paragraphs 1 through 31 and 34 above.
43. The action taken by defendants to publish false and defamatory statements impugning Dr.
Casey without providing Dr. Casey an opportunity to refute the false and defamatory statements was made
in bad faith with the intent to harm her fundamental rights to privacy and the pursuit of her livelihood.
44. Defendants actions violated Dr. Casey's fundamental right to privacy and her fundamental
right to the pursuit of her livelihood.
45. As a result of Dr. Casey's deprivation of the right to a hearing prior to the publication of the
false and derogatory statements, Dr. Casey has been damaged as alleged in paragraphs 37-39 above and
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is entitled to an award of attorneys fees and costs, including expert witness fees, as alleged in paragraph
40 above.
46. The comments and conduct of defendants Novotney and Stoops showed reckless or a
callous indifference to Dr. Casey's constitutional rights. Dr. Casey is entitled to an award of punitive
damages against these defendants.
THIRD CLAIM FOR RELIEF
(Against Defendant WESD)
(Breach of Contract)
48. WESD breached its employment contract with Dr. Casey by failing to promptly notify her
of the alleged concerns of Campbell and O'Connell; by failing to give her a due process hearing before the
Board formally adopted the 'findings of fact, conclusions and recommendations of the investigators; and
by terminating said employment contract.
49. WESD's Board of Director's formal adoption of the investigator's findings of fact and
conclusions at its meetings of September 22 and 25, 2009, was with the intent or purpose of terminating
Dr. Casey's employment. Under the terms of her Contract with WESD, Dr. Casey was entitled to a due
process hearing at, or before the September 22 or 25, 2009 meetings including, but not limited to: (1) a
hearing before an impartial tribunal; (2) an opportunity to present evidence and witnesses; (3) an
opportunity to cross-examine adverse witnesses; and (4) a decision by an impartial decision maker based
on evidence and findings of a hearing.
50. As a direct and proximate cause of WESD's breach of Dr. Casey's employment contract,
Dr. Casey has been damaged as alleged in paragraph 37 above.
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FOURTH CLAIM FOR RELIEF
(Against Defendant WESD)
(Defamation, Slander per se)
52. By the press releases and website postings as described in paragraphs 24-26 above,
defendant WESD made and published defamatory statements regarding Dr. Casey. The press releases
and website postings were false and defamatory per se because they implied that Dr. Casey had engaged
in bullying, violations of personnel policies, mismanagement and fiscal improprieties, all of which implied
a lack of integrity or unfitness in the discharge of her employment duties.
53. These published statements prejudiced Dr. Casey in her profession and diminished her
reputation.
54. As a result of Defendant WESD's defamatory statements, Dr. Casey has been damaged
as alleged in paragraphs 37-39 above.
FIFTH CLAIM FOR RELIEF
(Against Defendants WESD and Novotney)
56. By the statements of Novotney as described in paragraph 27 above, defendants WESD and
Novotney made and published defamatory statements regarding Dr. Casey, all of which implied a lack of
competency, honesty and trustworthiness.
57. If defendant Novotney made these statements in the scope of his employment or duties with
defendant WESD, WESD is legally liable for his conduct under ORS 30.265.
58. In the alternative, if defendant Novotney made the statements outside of the scope of his
employment or duties, defendant Novotney is personally liable for his conduct.
59. Defendants statements were false and defamatory per se because they implied that Dr.
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Casey had a lack of integrity or unfitness in the discharge of her duties.
reputation.
61. As a result of Defendants WESD and Novotney's defamatory statements, Dr. Casey has
been damaged as alleged in paragraphs 37-39 above.
SIXTH CLAIM FOR RELIEF
(Against Defendant Stoops)
63. By the statements of defendant Stoops as described in paragraph 30 above, defendant
Stoops made and published defamatory statements regarding Dr. Casey, all of which implied a lack of
competency, honesty and trustworthiness.
64. Defendant Stoops made these statements outside the scope of his Board duties with
WESD.
65. Defendant Stoops' statements were false and defamatory per se because they implied that
Dr. Casey had a lack of integrity or unfitness in the discharge of her duties.
reputation.
67. As a result of Defendant Stoops' defamatory statements, Dr. Casey has been damaged as
alleged in paragraphs 37-39 above.
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SEVENTH CLAIM FOR RELIEF
(Against Defendant Novotney)
(Intentional Interference with Economic Relations)
68. Plaintiff realleges and incorporates paragraphs 1 through 28 and 31 above.
69. Dr. Casey had a contractual relationship with WESD.
70. Defendant Novotney was not a party to that contractual relationship.
71. Defendant Novotney intended to interfere with Dr. Casey's contractual relationship, or knew
that such interference was substantially certain to occur 'from his actions.
72. Defendant Novotney interfered through improper means, orfor an improper purpose in one
or more of the ways alleged by Dr. Casey.
73. Defendant Novotney's interference caused harm to Dr. Casey's contractual relationship.
74. Defendant Novotney's interference resulted in damages to Dr. Casey as alleged in
paragraphs 37-39.
DEMAND FOR A JURY TRIAL
75. Plaintiff demands a jury trial.
Plaintiff prays for judgment as follows:
1. Against all defendants for economic damages from for her lost wages and benefits,
including contributions to her TSA and PERS accounts in an amount to be determined, but
estimated to be in the sum of $600,000, plus prejudgment interest in an amount to be
determined at trial;
2. Against defendant WESD for compensatory damages for humiliation and emotional distress
and damage to her personal and professional reputation in an amount to be determined,
but estimated to be in the sum of $800,000;
3. Against defendants Novotney and Stoops for compensatory damages for humiliation and
emotional distress and damage to her personal and professional reputation in an amount
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to be determined, but estimated to be in the sum of an additional $800,000;
4. Against defendants Novotney and Stoops for an award of punitive damages; and
5. Against all defendants for an award of her reasonable attorney's fees and costs, including
expert witness fees and costs and disbursements.
DATED this ~ a y of October, 2010
THE LAW OFFICES OF JUDY SNYDER
~
No. 732834
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Maureen Casey vs. WESD: Complaint

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