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RETURN DATE: JUNE 18, 2019 : SUPERIOR COURT
ANGELINA ANDREOLI : J.D. OF NEW HAVEN
vs. : AT NEW HAVEN
COMCAST CABLE COMMUNICATIONS
MANAGEMENT, LLC,CREDICO (USA) LLC,
AND WILLIAM C. MULLEN III ; MAY 15, 2019
COMPLAINT
COUNT ONE: SEX/GENDER DISCRIMINATION IN VIOLATION OF CONN.
GEN. STAT. § 46A-60(b)(1)
PLAINTIFF VS. COMCAST CABLE COMMUNICATIONS
MANAGEMENT, LLC
1. Plaintiff, Angelina Andreoli (‘Plaintiff’), was at all times relevant to this
Complaint, a resident of the City of New Haven, State of Connecticut. Plaintiff is
female.
2. At all times set forth herein, the Defendant, Comcast Cable
Communications, Management LLC (“COMCAST”) was a foreign corporation with a
business address of 1701 John F. Kennedy Boulevard, Philadelphia, PA, and was
transacting substantial business within the State of Connecticut. COMCAST is a
subsidiary of the Comcast Corporation, and uses the trade name “Xfinity” to market
consumer cable television, internet, telephone, and wireless services to thousands of
Connecticut residents.
3. At all times set forth herein, the Defendant, Credico (USA) LLC
(“CREDICO”), was a Delaware corporation headquartered in Chicago, Illinois. It
provides face-to-face sales and marketing services to companies in, inter alia, the
telecommunications industry. CREDICO’s clients include Defendant COMCAST, who
contracts with CREDICO, which, in turn employs and/or contracts with so-called
1“independent sales offices (“ISOs”) throughout the country to sell products and services
on behalf of CREDICO’s clientele. At all times relevant to this Complaint, CREDICO
engaged in substantial work of this nature in selling Xfinity products, on behalf of
COMCAST, to consumers within the State of Connecticut.
4. At all times set forth herein, the Defendant, William Mullen (“MULLEN”)
was a Resident of Westfield, Massachusetts, was an agent of COMCAST, and was a
Sales Executive working for COMCAST.
5. Prior to the initiation of this Action, Plaintiff filed a timely administrative
complaint against each of the Defendants with the Connecticut Commission on Human
Rights and Opportunities (“CHRO”). Thereafter, the CHRO issued Plaintiff Release of
Jurisdiction Letters for each of the named Defendants (EXHIBIT A). This Action is
brought within 90 days of receipt of said Release of Jurisdiction letters. As such,
Plaintiff has exhausted her administrative remedies, and this Action is timely.
6. At all times relevant hereto, and despite COMCAST and CREDICO
contractually misclassifying Plaintiff as an independent contractor, COMCAST and
CREDICO were Plaintiffs joint employers for the purposes of the Connecticut Fair
Employment Practices Act, other State and Federal employment laws, and the common
law, in that they each (but not by way of exclusion):
a. retained the power to hire and fire Plaintiff;
b. supervised and controlled Plaintiffs work schedules and conditions of
employment;
c. determined the rate and method of payment;
d. maintained records associated with the employment of Plaintiff,e. required the use of their respective premises and/or equipment,
uniforms, tools, promotional material, devices, computers, tablets,
netbooks, iPads, and software;
f. required Plaintiff to perform work to the exclusion of other employers or
opportunities;
g. set the prices for the products and services Plaintiff was required to
sell;
h. retained the right to audit records generated by Plaintiff in connection
with her employment; and
i. otherwise exerted control and authority over the terms and conditions
of Plaintiffs work consistent with that of an employer over an
employee.
7. Plaintiff commenced her employment with CREDICO in or about March of
2015, through an ISO, Aumni Group Inc., a Rhode Island corporation owned and
operated by an individual named Pranav Verma (“Verma”).
8. On or about June 26, 2017, Plaintiff commenced work with COMCAST
through CREDICO, when she undertook responsibilities for marketing and selling
COMCAST products and services pursuant to a “Scope of Work” defined by
COMCAST.
9. On or about that same date, Plaintiff attended a new vendor training
seminar at COMCAST's Berlin, Connecticut location, wherein COMCAST provided
training regarding its products, services, and the process in which Plaintiff was expected
to market and sell the same, and wherein Plaintiff first encountered DefendantMULLEN, a COMCAST Sales Executive who would ultimately serve as Plaintiff's
supervisor throughout the duration of her employment with COMCAST, and the
remainder of her employment with CREDICO.
10. Immediately, MULLEN subjected Plaintiff to what would evolve into a
continuing course of pervasive sexual harassment, discrimination, sexual propositions,
inappropriate sexual commentary, invasions of her personal space and privacy, and
unwanted and unsolicited touching of a sexual nature.
11. On or about June 26, 2017, for example, MULLEN, during the course of
the seminar, would ogle and stare at Plaintiff in a sexually suggestive and inappropriate
manner.
12. Shortly thereafter, and on or about June 30, 2017, Plaintiff and her team
members met with MULLEN for a business lunch at a Panera Bread restaurant located
in Hamden, Connecticut. During the course of the lunch, as the topic of conversation
turned toward the participants’ personal interests, MULLEN conveyed to the group that
he wanted to have a “team night” at the Cadillac Ranch in Southington, Connecticut,
noting that there was a mechanical bull at the establishment. In response, Plaintiff
conveyed that a week prior, she had almost gone on a mechanical bull, but decided
against it because she had forgotten to change out of her skirt. When Plaintiff then
attempted to direct the conversation toward business, MULLEN loudly inquired of
Plaintiff, in the middle of the restaurant and in front of Plaintiffs peers, “So you were
commando, like no panties?”
13. Shortly thereafter, on or about July 6, 2017, and again over the course of
another team lunch attended by Plaintiff, her team members, and MULLEN, Plaintiffwas discussing the fact that, after working at a local Wal-Mart in Hamden selling Xfinity
products, she went to a local nearby gym along with a peer, Anthony Catanzariti. In
response, MULLEN began awkwardly inquiring about which muscles Plaintiff was
working out, specifically asking wither she had worked out her legs, her “glutes” or her
chest, all while in Plaintiff's presence.
14. Immediately after the foregoing exchange, Plaintiff complained to Verma,
a colleague, who in turn, reported Plaintiffs concerns regarding MULLEN’s
inappropriate sexual commentary to COMCAST.
15. In or about July of 2017, Plaintiff commenced performing her work for
CREDICO and COMCAST through an entity known as “Gianni Rae Associates, Inc.”
16. Despite COMCAST being made aware of MULLEN’s inappropriate sexual
commentary at the virtual outset of Plaintiffs employment, COMCAST did nothing to
curtail the conduct, and as such, it was allowed to persist, and worsen over the coming
weeks and months.
17. For example, MULLEN would, on a near daily basis, arrive at Plaintiff's
office as she was attempting to hold a meeting or a workshop concerning her team’s
work for COMCAST in selling Xfinity products, and insist that Plaintiff give him a hug,
oftentimes interrupting Plaintiff in the middle of a meeting to do so. Each time, MULLEN
would approach Plaintiff, open his arms, and state in words or substance, “You know
what you have to do.”
18. Ona host of occasions, MULLEN would also approach Plaintiff, tug on her
hair, and convey to Plaintiff, in words or substance, “Oh, darling, you know how much |
love when your hair's up in a ponytail.” In response, Plaintiff unambiguously instructedMULLEN to stop. MULLEN laughed in response, despite the fact that Plaintiff and her
peers conveyed to him that the situation was not funny.
19. On or around July 20, 2017, while Plaintiff was walking into a Dunkin’
Donuts with MULLEN, MULLEN stated to Plaintiff, “Oh, darling, that skirt fits your ass
just so damn freaking perfect.”
20. On or about the fourth occasion on which Plaintiff attended a “business”
lunch with MULLEN, MULLEN insisted on turning the conversation toward sex. During
the course of the conversation, for instance, MULLEN began bragging about his sex life
with women in Thailand, and conveyed to Plaintiff that he had purportedly had sexual
relations with a 24-year-old lesbian, whom he claimed to have “turned straight.”
Following this anecdote, MULLEN stated to Plaintiff, “If you weren't a lesbian, you would
let me relax you and have some fun.” Again, Plaintiff was unambiguous in her rejection
of MULLEN’s repeated sexual advances.
21. On still a separate occasion, MULLEN invited Plaintiff and her colleagues
to participate in a “Rugged Maniac” competition, wherein the participants traverse a
muddy obstacle course, on the premise that it would be a team-building exercise.
MULLEN offered for Plaintiff to spend the evening after the race at his home. Again,
Plaintiff refused.
22. The unsolicited physical contact persisted, and worsened thereafter. In or
about August of 2017, whenever Plaintiff attempted to discuss COMCAST business with
MULLEN, MULLEN would enter into Plaintiff's office, place his hands on Plaintiff's neck,
and attempt to begin to massage Plaintiff's neck and shoulders, stating to her, in words
or substance, “You need it, darling.”23. Over the course of the next several months, MULLEN also began covertly
record videos of Plaintiff and take photographs of her without her permission or consent,
and despite the fact that such photographs and/or recordings were taken of Plaintiff in
situations wherein she had a reasonable expectation of privacy.
24. In still another instance, and on or about November 2, 2017, MULLEN
attempted to play “footsies” with Plaintiff while attending another “business” dinner at a
Japanese restaurant. When Plaintiff stated to MULLEN to “stop kicking [her],”
MULLEN stated to Plaintiff, in words or substance, “I’m just playing footsies, sweet
thang.”
25. Between approximately November 2017 and January 2018, each time
MULLEN would force Plaintiff to give him a hug, he would surreptitiously attempt to
grope Plaintiffs breasts. When called on this behavior by Plaintiff, MULLEN would
insist that it was unintentional. He would, however, persist in this conduct for months.
26. In or about January of 2018, Plaintiff complained directly to COMCAST
concerning the hostile work environment to which she had been subjected, by way of a
complaint to Brian Burke, COMCAST’s Regional Manager, wherein she conveyed
several of the aforesaid incidents involving MULLEN. During the course of the ensuing
conversation, Burke conveyed to Plaintiff that he had been aware of Plaintiffs earlier
complaints, and assured Plaintiff that MULLEN would be dealt with and that he would
no longer be working with Plaintiff.
27. Despite Burke’s representations, MULLEN appeared in Plaintiff's office,
uninvited, within days of Plaintiff's prior meeting with Burke.28. Thereafter, and on or about January 25, 2018, while Plaintiff was
attending a “Partners Summit” hosted by COMCAST, Richard Bates, COMCAST’s
Senior Manager of National Accounts, attempted to brazenly grab Plaintiff's face and
kiss her, despite the advance being wholly unsolicited. In response, Plaintiff slapped
Bates, and removed herself from the situation.
29. Based on the foregoing conduct, Plaintiff was left with no choice but to
cease work with Defendants COMCAST and CREDICO.
30. COMCAST and CREDICO, through their respective managers,
executives, agents and employees, subjected Plaintiff to discrimination on account of
her sex and gender, subjected her to a hostile work environment, subjected her to
sexual harassment, and subjected her to multiple sexual assaults and batteries, all of
which had the effect of substantially interfering with her ability to function in her position
and perform her job.
31. At all times mentioned herein above, CREDICO and COMCAST had the
ability and authority to curtail the aforesaid conduct, of which it was aware, and
deliberately or willfully ignored the same, ensuring that the same would persist.
32. MULLEN, as aforesaid, aided, abetted, coerced, incited, or compelled the
discriminatory employment practices described herein above.
33. | The Defendants discriminated against Plaintiff on the basis of her sex and
her gender in violation of Conn. Gen. Stat. §46a-60(b)(1).
34. As a result of the aforesaid unlawful conduct, Plaintiff has sustained lost
wages, has been deprived of the benefits of gainful employment into the future, hassustained significant emotional distress damages, and has incurred or will incur
significant attorneys’ fees and costs in order to secure her rights.
COUNT TWO: = SEXUAL HARASSMENT IN VIOLATION OF CONN. GEN. STAT.
§ 46A-60(B)(8)
PLAINTIFF VS. COMCAST CABLE COMMUNICATIONS
MANAGEMENT, LLC
1. Paragraphs 1 through 32 of Count One are hereby repeated and re-
alleged as Paragraphs 1 through 32 of this Count Two as if fully set forth herein.
33. COMCAST, by itself or through its agent, subjected Plaintiff to a
continuing course of sexual harassment, unwelcome sexual advances, requests for
sexual favors, and other conduct of a sexual nature. Submission to such conduct was
made explicitly or implicity a term or condition of Plaintiff's continued employment.
Such conduct had the purpose or effect of substantially interfering with Plaintiff's work
performance and/or created an intimidating, hostile, and offensive working environment.
34. As a result of the aforesaid unlawful conduct, Plaintiff has sustained lost
wages, has been deprived of the benefits of gainful employment into the future, has
sustained significant emotional distress damages, has suffered a diminution in her
earning capacity, and has incurred or will incur significant attorneys’ fees and costs in
order to secure her rights.
COUNT THREE: COMMON LAW NEGLIGENT SUPERVISION
PLAINTIFF VS. COMCAST CABLE COMMUNICATIONS
MANAGEMENT, LLC
1. Paragraphs 1 through 32 of Count One are hereby repeated and re-
alleged as Paragraphs 1 through 32 of this Count Three as if fully set forth herein.33. At all times relevant, MULLEN acted as a servant or agent of COMCAST,
utilized COMCAST resources and/or chattel, and utilized his position of authority and
supervisory control over Plaintiff which he had by virtue of his employment with
COMCAST, in perpetrating the aforesaid unlawful conduct delineated hereinabove—
namely, that MULLEN subjected Plaintiff to numerous sexual assaults and batteries in
the course and scope of his employment with COMCAST, and intentionally and/or
negligently inflicted emotional distress upon the Plaintiff in the course and scope of his
employment with COMCAST.
34. At all times relevant, COMCAST knew or had reason to know that it could
control MULLEN’s conduct and recognized the necessity of doing so, by virtue of the
fact that it had received complaints concerning MULLEN’s conduct.
35. Asa result of the aforesaid unlawful conduct, Plaintiff has sustained lost
wages, has been deprived of the benefits of gainful employment into the future, has
sustained significant emotional distress damages, and has suffered a diminution in her
earning capacity.
COUNT FOUR: —SEX/GENDER DISCRIMINATION IN VIOLATION OF CONN.
GEN. STAT. § 46A-60(B)(1)
PLAINTIFF VS. CREDICO (USA) LLC
1. Paragraphs 1 through 32 of Count One are hereby repeated and re-
alleged as Paragraphs 1 through 32 of this Count Four as if fully set forth herein.
33. | The Defendants discriminated against Plaintiff on the basis of her sex and
her gender in violation of Conn. Gen. Stat. §46a-60(b)(1).
34. As a result of the aforesaid unlawful conduct, Plaintiff has sustained lost
wages, has been deprived of the benefits of gainful employment into the future, has
10sustained significant emotional distress damages, and has incurred or will incur
significant attorneys’ fees and costs in order to secure her rights.
COUNT FIVE: SEXUAL HARASSMENT IN VIOLATION OF CONN. GEN. STAT.
§ 46A-60(B)(8)
PLAINTIFF VS. CREDICO (USA) LLC
1. Paragraphs 1 through 32 of Count One are hereby repeated and re-
alleged as Paragraphs 1 through 32 of this Count Two as if fully set forth herein.
33. | CREDICO subjected Plaintiff to a continuing course of sexual harassment,
unwelcome sexual advances, requests for sexual favors, and other conduct of a sexual
nature. Submission to such conduct was made explicitly or implicity a term or condition
of Plaintiffs continued employment. Such conduct had the purpose or effect of
substantially interfering with Plaintiff's work performance and/or created an intimidating,
hostile, and offensive working environment.
34. Asa result of the aforesaid unlawful conduct, Plaintiff has sustained lost
wages, has been deprived of the benefits of gainful employment into the future, has
sustained significant emotional distress damages, has suffered a diminution in her
earning capacity, and has incurred or will incur significant attorneys’ fees and costs in
order to secure her rights.
COUNT SIX: AIDING, ABETTING, INCITING, COMPELLING, OR COERCING
OF DISCRIMINATORY PRACTICES IN VIOLATION OF CONN.
GEN. STAT. § 46A-60(B)(5)
PLAINTIFF VS. WILLIAM C. MULLEN III
1. Paragraphs 1 through 32 of Count One are hereby repeated and re-
alleged as Paragraphs 1 through 32 of this Count Six as if fully set forth herein.
1133. MULLEN aided, abetted, compelled, or coerced the discriminatory
employment practices described hereinabove, in that he discriminated against her on
the bases of her sex and/or gender, and subjected Plaintiff to a continuing course of
sexual harassment, unwelcome sexual advances, requests for sexual favors, and other
conduct of a sexual nature. Submission to such conduct was made explicitly or implicity
a term or condition of Plaintiff's continued employment. Such conduct had the purpose
or effect of substantially interfering with Plaintiffs work performance and/or created an
intimidating, hostile, and offensive working environment.
34. As a result of the aforesaid unlawful conduct, Plaintiff has sustained lost
wages, has been deprived of the benefits of gainful employment into the future, has
sustained significant emotional distress damages, has suffered a diminution in her
earning capacity, and has incurred or will incur significant attorneys’ fees and costs in
order to secure her rights.
COUNT SEVEN: COMMON LAW ASSAULT AND BATTERY
PLAINTIFF VS. WILLIAM C. MULLEN III
1. Paragraphs 1 through 32 of Count One are hereby repeated and re-
alleged as Paragraphs 1 through 32 of this Count Seven as if fully set forth herein.
33. MULLEN’s conduct, as delineated hereinabove, constituted multiple
instances of assault and battery upon the Plaintiff.
34. As a result of the aforesaid unlawful conduct, has sustained significant
emotional distress damages, has suffered a diminution in her earning capacity, and has
sustained other losses and damages to her detriment.
12COUNT EIGHT: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
PLAINTIFF VS. WILLIAM C. MULLEN III
de Paragraphs 1 through 32 of Count One are hereby repeated and re-
alleged as Paragraphs 1 through 32 of this Count Eight as if fully set forth herein.
33. | MULLEN negligently inflicted emotional distress upon the Plaintiff by virtue
of the foregoing conduct.
34. MULLEN’s conduct created an unreasonable risk of causing Plaintiff
emotional distress.
35. Plaintiff's emotional distress was foreseeable to MULLEN, and his conduct
was of such a nature that he was aware or should have been aware that there was risk
of illness or bodily harm to Plaintiff.
36. As a result of the MULLEN’s unlawful conduct, Plaintiff has sustained
severe emotional distress damages, has suffered a diminution in her earning capacity,
and has sustained other losses and damages to her detriment.
COUNT NINE: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
PLAINTIFF VS. WILLIAM C. MULLEN III
le Paragraphs 1 through 32 of Count One are hereby repeated and re-
alleged as Paragraphs 1 through 32 of this Count Nine as if fully set forth herein.
33. MULLEN intentionally inflicted emotional distress upon the Plaintiff by
virtue of the foregoing conduct.
34. | MULLEN’s either intended to inflict emotional distress upon the Plaintiff or
knew or should have known that emotional distress was the likely result of his conduct.
35: MULLEN’s conduct, as aforesaid, was extreme and outrageous.
1336. Plaintiff's emotional distress was foreseeable to MULLEN, and his conduct
was of such a nature that he was aware or should have been aware that there was risk
of illness or bodily harm to Plaintiff.
37. As a result of the MULLEN’s unlawful conduct, Plaintiff has sustained
severe emotional distress damages, has suffered a diminution in her earning capacity,
and has sustained other losses and damages to her detriment.
PLAINTIFF,
ANGELINA ANDREOLI
364 Franklin Avenue
Hartford, CT 06114
Tel: (860) 296-3457
Fax: (860) 296-0676
Juris No.: 419987
Email: mparadisi@cicchielloesq.com
14RETURN DATE: JUNE 18, 2019 : SUPERIOR COURT
ANGELINA ANDREOLI : J.D. OF NEW HAVEN
Vs. : AT NEW HAVEN
COMCAST CABLE COMMUNICATIONS
MANAGEMENT, LLC,CREDICO (USA) LLC,
AND WILLIAM C. MULLEN III : MAY 15, 2019
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for the following relief:
Money damages;
Costs of this Action;
Attorneys fees pursuant to Conn. Gen. Stat. § 46a-104;
Punitive damages as to Count Nine; and
All other awardable relief.
gPon>
PLAINTIFF,
ANGELINA ANDREOLI
chiello & Cicchiello, LLP
364 Franklin Avenue
Hartford, CT 06114
Tel: (860) 296-3457
Fax: (860) 296-0676
Juris No.: 419987
Email: mparadisi@cicchielloesg.com
15RETURN DATE: JUNE 18, 2019 : SUPERIOR COURT
ANGELINA ANDREOLI J.D. OF NEW HAVEN
Vs. : AT NEW HAVEN
COMCAST CABLE COMMUNICATIONS
MANAGEMENT, LLC,CREDICO (USA) LLC,
AND WILLIAM C. MULLEN Ill | MAY 15, 2019
STATEMENT OF AMOUNT IN DEMAND
The amount in demand is in excess of $15,000.00, exclusive of interest and costs.
PLAINTIFF,
ANGELINA ANDREOLI
. Paradisi
Cicchiello & Cicchiello, LLP
364 Franklin Avenue
Hartford, CT 06114
Tel: (860) 296-3457
Fax: (860) 296-0676
Juris No.: 419987
Email: mparadisi@cicchielloesg.com
16EXHIBIT ASTATE OF CONNECTICUT
COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES
Angelina Andreoli
COMPLAINANT
CHRO No. 1930169
vs. EEOC No. 16A201900087
Comcast of Connecticut Inc.
RESPONDENT
RELEASE OF JURISDICTION
The Commission on Human Rights and Opportunities hereby releases its jurisdiction over the above-
identified complaint. The Complainant is authorized to commence a civil action in accordance with
CONN. GEN. STAT. § 46a-100 against the Respondent in the Superior Court for the judicial
district in which the discriminatory practice is alleged to have occurred, in which the Respondent
transacts business or in which the Complainant resides. If this action involves a state agency or
Official, it nay be brought in the Superior Court for the judicial district of Hartford.
A copy of any civil action brought pursuant to this release must be served on the Commission at
ROJ@ct.gov or at 450 Columbus Blvd., Suite 2, Hartford, CT 06103 at the same time all other
parties are served. Electronic service is preferred. THE COMMISSION MUST BE SERVED
BECAUSE IT HAS A RIGHT TO INTERVENE IN ANY ACTION BASED ON A RELEASE
OF JURISDICTION PURSUANT TO CONN. GEN. STAT. § 46a-103._
The Complainant must bring an action in Superior Court within 90 days of receipt of this release and
within two years of the date of filing the complaint with the Commission unless
circumstances tolling the statute of limitations are present.
Saenger Ago
DATE: March 21, 2019 Tanya A. Hughes, Executive Director
Service:
Complainant: mparadisi@cicchielloesg.com
Complainant's attorney: mparadisi@cicchielloesg.com
Respondent: Comcast of Connecticut Inc
Respondent's attorney: jfritz@fisherphillips.comSTATE OF CONNECTICUT
COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES
Angelina Andreoli
COMPLAINANT
CHRO No. 1930401
vs. EEOC No. 16A201900484
Credico (USA)
RESPONDENT
RELEASE OF JURISDICTION
The Commission on Human Rights and Opportunities hereby releases its jurisdiction over the above-
identified complaint. The Complainant is authorized to commence a civil action in accordance with
CONN. GEN. STAT. § 46a-100 against the Respondent in the Superior Court for the judicial
district in which the discriminatory practice is alleged to have occurred, in which the Respondent
transacts business or in which the Complainant resides. If this action involves a state agency or
Official, it may be brought in the Superior Court for the judicial district of Hartford.
A copy of any civil action brought pursuant to this release must be served on the Commission at
ROJ@ct.gov or at 450 Columbus Blvd., Suite 2, Hartford, CT 06103 at the same time all other
parties are served. Electronic service is preferred. THE COMMISSION MUST BE SERVED
BECAUSE IT HAS A RIGHT TO INTERVENE IN ANY ACTION BASED ON A RELEASE
OF JURISDICTION PURSUANT TO CONN. GEN. STAT. § 46a-103._
The Complainant must bring an action in Superior Court within 90 days of receipt of this release and
within two years of the date of filing the complaint with the Commission unless
circumstances tolling the statute of limitations are present.
= Junge ADM ig Pos
DATE: March 21, 2019 Tanya A. Hughes, Executive Director
Service:
Complainant: mparadisi@cicchielloesq.com
Complainant's attorney: mparadisi@cicchielloesg.com
Respondent: Credico (US)
Respondent's attorney: acalifano@seyfarth.comSTATE OF CONNECTICUT
COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES
Angelina Andreoli
COMPLAINANT
CHRO No. 1930428
vs. EEOC No. N/A
William Mullen
RESPONDENT
RELEASE OF JURISDICTION
The Commission on Human Rights and Opportunities hereby releases its jurisdiction over the above-
identified complaint. The Complainant is authorized to commence a civil action in accordance with
CONN. GEN. STAT. § 46a-100 against the Respondent in the Superior Court for the judicial
district in which the discriminatory practice is alleged to have occurred, in which the Respondent
transacts business or in which the Complainant resides. If this action involves a state agency or
Official, it may be brought in the Superior Court for the judicial district of Hartford.
A copy of any civil action brought pursuant to this release must be served on the Commission at
ROJ@ct.gov or at 450 Columbus Blvd., Suite 2, Hartford, CT 06103 at the same time all other
parties are served. Electronic service is preferred. THE COMMISSION MUST BE SERVED
BECAUSE IT HAS A RIGHT TO INTERVENE IN ANY ACTION BASED ON A RELEASE
OF JURISDICTION PURSUANT TO CONN. GEN. STAT. § 46a-103._
The Complainant must bring an action in Superior Court within 90 days of receipt of this release and
within two years of the date of filing the complaint with the Commission unless
circumstances tolling the statute of limitations are present.
—Sange AWM gA as
DATE: March 21, 2019 Tanya A. Hughes, Executive Director
Service:
Complainant: mparadisi@cicchielloesq.com
Complainant's attorney: mparadisi@cicchielloesq.com
Respondent: William Mullen — via regular mail
Respondent's attorney: n/a
Preview
RETURN DATE: JUNE 18, 2019 : SUPERIOR COURT ANGELINA ANDREOLI : J.D. OF NEW HAVEN vs. : AT NEW HAVEN COMCAST CABLE COMMUNICATIONS MANAGEMENT, LLC,CREDICO (USA) LLC, AND WILLIAM C. MULLEN III ; MAY 15, 2019 COMPLAINT COUNT ONE: SEX/GENDER DISCRIMINATION IN VIOLATION OF CONN. GEN. STAT. § 46A-60(b)(1) PLAINTIFF VS. COMCAST CABLE COMMUNICATIONS MANAGEMENT, LLC 1. Plaintiff, Angelina Andreoli (‘Plaintiff’), was at all times relevant to this Complaint, a resident of the City of New Haven, State of Connecticut. Plaintiff is female. 2. At all times set forth herein, the Defendant, Comcast Cable Communications, Management LLC (“COMCAST”) was a foreign corporation with a business address of 1701 John F. Kennedy Boulevard, Philadelphia, PA, and was transacting substantial business within the State of Connecticut. COMCAST is a subsidiary of the Comcast Corporation, and uses the trade name “Xfinity” to market consumer cable television, internet, telephone, and wireless services to thousands of Connecticut residents. 3. At all times set forth herein, the Defendant, Credico (USA) LLC (“CREDICO”), was a Delaware corporation headquartered in Chicago, Illinois. It provides face-to-face sales and marketing services to companies in, inter alia, the telecommunications industry. CREDICO’s clients include Defendant COMCAST, who contracts with CREDICO, which, in turn employs and/or contracts with so-called 1“independent sales offices (“ISOs”) throughout the country to sell products and services on behalf of CREDICO’s clientele. At all times relevant to this Complaint, CREDICO engaged in substantial work of this nature in selling Xfinity products, on behalf of COMCAST, to consumers within the State of Connecticut. 4. At all times set forth herein, the Defendant, William Mullen (“MULLEN”) was a Resident of Westfield, Massachusetts, was an agent of COMCAST, and was a Sales Executive working for COMCAST. 5. Prior to the initiation of this Action, Plaintiff filed a timely administrative complaint against each of the Defendants with the Connecticut Commission on Human Rights and Opportunities (“CHRO”). Thereafter, the CHRO issued Plaintiff Release of Jurisdiction Letters for each of the named Defendants (EXHIBIT A). This Action is brought within 90 days of receipt of said Release of Jurisdiction letters. As such, Plaintiff has exhausted her administrative remedies, and this Action is timely. 6. At all times relevant hereto, and despite COMCAST and CREDICO contractually misclassifying Plaintiff as an independent contractor, COMCAST and CREDICO were Plaintiffs joint employers for the purposes of the Connecticut Fair Employment Practices Act, other State and Federal employment laws, and the common law, in that they each (but not by way of exclusion): a. retained the power to hire and fire Plaintiff; b. supervised and controlled Plaintiffs work schedules and conditions of employment; c. determined the rate and method of payment; d. maintained records associated with the employment of Plaintiff,e. required the use of their respective premises and/or equipment, uniforms, tools, promotional material, devices, computers, tablets, netbooks, iPads, and software; f. required Plaintiff to perform work to the exclusion of other employers or opportunities; g. set the prices for the products and services Plaintiff was required to sell; h. retained the right to audit records generated by Plaintiff in connection with her employment; and i. otherwise exerted control and authority over the terms and conditions of Plaintiffs work consistent with that of an employer over an employee. 7. Plaintiff commenced her employment with CREDICO in or about March of 2015, through an ISO, Aumni Group Inc., a Rhode Island corporation owned and operated by an individual named Pranav Verma (“Verma”). 8. On or about June 26, 2017, Plaintiff commenced work with COMCAST through CREDICO, when she undertook responsibilities for marketing and selling COMCAST products and services pursuant to a “Scope of Work” defined by COMCAST. 9. On or about that same date, Plaintiff attended a new vendor training seminar at COMCAST's Berlin, Connecticut location, wherein COMCAST provided training regarding its products, services, and the process in which Plaintiff was expected to market and sell the same, and wherein Plaintiff first encountered DefendantMULLEN, a COMCAST Sales Executive who would ultimately serve as Plaintiff's supervisor throughout the duration of her employment with COMCAST, and the remainder of her employment with CREDICO. 10. Immediately, MULLEN subjected Plaintiff to what would evolve into a continuing course of pervasive sexual harassment, discrimination, sexual propositions, inappropriate sexual commentary, invasions of her personal space and privacy, and unwanted and unsolicited touching of a sexual nature. 11. On or about June 26, 2017, for example, MULLEN, during the course of the seminar, would ogle and stare at Plaintiff in a sexually suggestive and inappropriate manner. 12. Shortly thereafter, and on or about June 30, 2017, Plaintiff and her team members met with MULLEN for a business lunch at a Panera Bread restaurant located in Hamden, Connecticut. During the course of the lunch, as the topic of conversation turned toward the participants’ personal interests, MULLEN conveyed to the group that he wanted to have a “team night” at the Cadillac Ranch in Southington, Connecticut, noting that there was a mechanical bull at the establishment. In response, Plaintiff conveyed that a week prior, she had almost gone on a mechanical bull, but decided against it because she had forgotten to change out of her skirt. When Plaintiff then attempted to direct the conversation toward business, MULLEN loudly inquired of Plaintiff, in the middle of the restaurant and in front of Plaintiffs peers, “So you were commando, like no panties?” 13. Shortly thereafter, on or about July 6, 2017, and again over the course of another team lunch attended by Plaintiff, her team members, and MULLEN, Plaintiffwas discussing the fact that, after working at a local Wal-Mart in Hamden selling Xfinity products, she went to a local nearby gym along with a peer, Anthony Catanzariti. In response, MULLEN began awkwardly inquiring about which muscles Plaintiff was working out, specifically asking wither she had worked out her legs, her “glutes” or her chest, all while in Plaintiff's presence. 14. Immediately after the foregoing exchange, Plaintiff complained to Verma, a colleague, who in turn, reported Plaintiffs concerns regarding MULLEN’s inappropriate sexual commentary to COMCAST. 15. In or about July of 2017, Plaintiff commenced performing her work for CREDICO and COMCAST through an entity known as “Gianni Rae Associates, Inc.” 16. Despite COMCAST being made aware of MULLEN’s inappropriate sexual commentary at the virtual outset of Plaintiffs employment, COMCAST did nothing to curtail the conduct, and as such, it was allowed to persist, and worsen over the coming weeks and months. 17. For example, MULLEN would, on a near daily basis, arrive at Plaintiff's office as she was attempting to hold a meeting or a workshop concerning her team’s work for COMCAST in selling Xfinity products, and insist that Plaintiff give him a hug, oftentimes interrupting Plaintiff in the middle of a meeting to do so. Each time, MULLEN would approach Plaintiff, open his arms, and state in words or substance, “You know what you have to do.” 18. Ona host of occasions, MULLEN would also approach Plaintiff, tug on her hair, and convey to Plaintiff, in words or substance, “Oh, darling, you know how much | love when your hair's up in a ponytail.” In response, Plaintiff unambiguously instructedMULLEN to stop. MULLEN laughed in response, despite the fact that Plaintiff and her peers conveyed to him that the situation was not funny. 19. On or around July 20, 2017, while Plaintiff was walking into a Dunkin’ Donuts with MULLEN, MULLEN stated to Plaintiff, “Oh, darling, that skirt fits your ass just so damn freaking perfect.” 20. On or about the fourth occasion on which Plaintiff attended a “business” lunch with MULLEN, MULLEN insisted on turning the conversation toward sex. During the course of the conversation, for instance, MULLEN began bragging about his sex life with women in Thailand, and conveyed to Plaintiff that he had purportedly had sexual relations with a 24-year-old lesbian, whom he claimed to have “turned straight.” Following this anecdote, MULLEN stated to Plaintiff, “If you weren't a lesbian, you would let me relax you and have some fun.” Again, Plaintiff was unambiguous in her rejection of MULLEN’s repeated sexual advances. 21. On still a separate occasion, MULLEN invited Plaintiff and her colleagues to participate in a “Rugged Maniac” competition, wherein the participants traverse a muddy obstacle course, on the premise that it would be a team-building exercise. MULLEN offered for Plaintiff to spend the evening after the race at his home. Again, Plaintiff refused. 22. The unsolicited physical contact persisted, and worsened thereafter. In or about August of 2017, whenever Plaintiff attempted to discuss COMCAST business with MULLEN, MULLEN would enter into Plaintiff's office, place his hands on Plaintiff's neck, and attempt to begin to massage Plaintiff's neck and shoulders, stating to her, in words or substance, “You need it, darling.”23. Over the course of the next several months, MULLEN also began covertly record videos of Plaintiff and take photographs of her without her permission or consent, and despite the fact that such photographs and/or recordings were taken of Plaintiff in situations wherein she had a reasonable expectation of privacy. 24. In still another instance, and on or about November 2, 2017, MULLEN attempted to play “footsies” with Plaintiff while attending another “business” dinner at a Japanese restaurant. When Plaintiff stated to MULLEN to “stop kicking [her],” MULLEN stated to Plaintiff, in words or substance, “I’m just playing footsies, sweet thang.” 25. Between approximately November 2017 and January 2018, each time MULLEN would force Plaintiff to give him a hug, he would surreptitiously attempt to grope Plaintiffs breasts. When called on this behavior by Plaintiff, MULLEN would insist that it was unintentional. He would, however, persist in this conduct for months. 26. In or about January of 2018, Plaintiff complained directly to COMCAST concerning the hostile work environment to which she had been subjected, by way of a complaint to Brian Burke, COMCAST’s Regional Manager, wherein she conveyed several of the aforesaid incidents involving MULLEN. During the course of the ensuing conversation, Burke conveyed to Plaintiff that he had been aware of Plaintiffs earlier complaints, and assured Plaintiff that MULLEN would be dealt with and that he would no longer be working with Plaintiff. 27. Despite Burke’s representations, MULLEN appeared in Plaintiff's office, uninvited, within days of Plaintiff's prior meeting with Burke.28. Thereafter, and on or about January 25, 2018, while Plaintiff was attending a “Partners Summit” hosted by COMCAST, Richard Bates, COMCAST’s Senior Manager of National Accounts, attempted to brazenly grab Plaintiff's face and kiss her, despite the advance being wholly unsolicited. In response, Plaintiff slapped Bates, and removed herself from the situation. 29. Based on the foregoing conduct, Plaintiff was left with no choice but to cease work with Defendants COMCAST and CREDICO. 30. COMCAST and CREDICO, through their respective managers, executives, agents and employees, subjected Plaintiff to discrimination on account of her sex and gender, subjected her to a hostile work environment, subjected her to sexual harassment, and subjected her to multiple sexual assaults and batteries, all of which had the effect of substantially interfering with her ability to function in her position and perform her job. 31. At all times mentioned herein above, CREDICO and COMCAST had the ability and authority to curtail the aforesaid conduct, of which it was aware, and deliberately or willfully ignored the same, ensuring that the same would persist. 32. MULLEN, as aforesaid, aided, abetted, coerced, incited, or compelled the discriminatory employment practices described herein above. 33. | The Defendants discriminated against Plaintiff on the basis of her sex and her gender in violation of Conn. Gen. Stat. §46a-60(b)(1). 34. As a result of the aforesaid unlawful conduct, Plaintiff has sustained lost wages, has been deprived of the benefits of gainful employment into the future, hassustained significant emotional distress damages, and has incurred or will incur significant attorneys’ fees and costs in order to secure her rights. COUNT TWO: = SEXUAL HARASSMENT IN VIOLATION OF CONN. GEN. STAT. § 46A-60(B)(8) PLAINTIFF VS. COMCAST CABLE COMMUNICATIONS MANAGEMENT, LLC 1. Paragraphs 1 through 32 of Count One are hereby repeated and re- alleged as Paragraphs 1 through 32 of this Count Two as if fully set forth herein. 33. COMCAST, by itself or through its agent, subjected Plaintiff to a continuing course of sexual harassment, unwelcome sexual advances, requests for sexual favors, and other conduct of a sexual nature. Submission to such conduct was made explicitly or implicity a term or condition of Plaintiff's continued employment. Such conduct had the purpose or effect of substantially interfering with Plaintiff's work performance and/or created an intimidating, hostile, and offensive working environment. 34. As a result of the aforesaid unlawful conduct, Plaintiff has sustained lost wages, has been deprived of the benefits of gainful employment into the future, has sustained significant emotional distress damages, has suffered a diminution in her earning capacity, and has incurred or will incur significant attorneys’ fees and costs in order to secure her rights. COUNT THREE: COMMON LAW NEGLIGENT SUPERVISION PLAINTIFF VS. COMCAST CABLE COMMUNICATIONS MANAGEMENT, LLC 1. Paragraphs 1 through 32 of Count One are hereby repeated and re- alleged as Paragraphs 1 through 32 of this Count Three as if fully set forth herein.33. At all times relevant, MULLEN acted as a servant or agent of COMCAST, utilized COMCAST resources and/or chattel, and utilized his position of authority and supervisory control over Plaintiff which he had by virtue of his employment with COMCAST, in perpetrating the aforesaid unlawful conduct delineated hereinabove— namely, that MULLEN subjected Plaintiff to numerous sexual assaults and batteries in the course and scope of his employment with COMCAST, and intentionally and/or negligently inflicted emotional distress upon the Plaintiff in the course and scope of his employment with COMCAST. 34. At all times relevant, COMCAST knew or had reason to know that it could control MULLEN’s conduct and recognized the necessity of doing so, by virtue of the fact that it had received complaints concerning MULLEN’s conduct. 35. Asa result of the aforesaid unlawful conduct, Plaintiff has sustained lost wages, has been deprived of the benefits of gainful employment into the future, has sustained significant emotional distress damages, and has suffered a diminution in her earning capacity. COUNT FOUR: —SEX/GENDER DISCRIMINATION IN VIOLATION OF CONN. GEN. STAT. § 46A-60(B)(1) PLAINTIFF VS. CREDICO (USA) LLC 1. Paragraphs 1 through 32 of Count One are hereby repeated and re- alleged as Paragraphs 1 through 32 of this Count Four as if fully set forth herein. 33. | The Defendants discriminated against Plaintiff on the basis of her sex and her gender in violation of Conn. Gen. Stat. §46a-60(b)(1). 34. As a result of the aforesaid unlawful conduct, Plaintiff has sustained lost wages, has been deprived of the benefits of gainful employment into the future, has 10sustained significant emotional distress damages, and has incurred or will incur significant attorneys’ fees and costs in order to secure her rights. COUNT FIVE: SEXUAL HARASSMENT IN VIOLATION OF CONN. GEN. STAT. § 46A-60(B)(8) PLAINTIFF VS. CREDICO (USA) LLC 1. Paragraphs 1 through 32 of Count One are hereby repeated and re- alleged as Paragraphs 1 through 32 of this Count Two as if fully set forth herein. 33. | CREDICO subjected Plaintiff to a continuing course of sexual harassment, unwelcome sexual advances, requests for sexual favors, and other conduct of a sexual nature. Submission to such conduct was made explicitly or implicity a term or condition of Plaintiffs continued employment. Such conduct had the purpose or effect of substantially interfering with Plaintiff's work performance and/or created an intimidating, hostile, and offensive working environment. 34. Asa result of the aforesaid unlawful conduct, Plaintiff has sustained lost wages, has been deprived of the benefits of gainful employment into the future, has sustained significant emotional distress damages, has suffered a diminution in her earning capacity, and has incurred or will incur significant attorneys’ fees and costs in order to secure her rights. COUNT SIX: AIDING, ABETTING, INCITING, COMPELLING, OR COERCING OF DISCRIMINATORY PRACTICES IN VIOLATION OF CONN. GEN. STAT. § 46A-60(B)(5) PLAINTIFF VS. WILLIAM C. MULLEN III 1. Paragraphs 1 through 32 of Count One are hereby repeated and re- alleged as Paragraphs 1 through 32 of this Count Six as if fully set forth herein. 1133. MULLEN aided, abetted, compelled, or coerced the discriminatory employment practices described hereinabove, in that he discriminated against her on the bases of her sex and/or gender, and subjected Plaintiff to a continuing course of sexual harassment, unwelcome sexual advances, requests for sexual favors, and other conduct of a sexual nature. Submission to such conduct was made explicitly or implicity a term or condition of Plaintiff's continued employment. Such conduct had the purpose or effect of substantially interfering with Plaintiffs work performance and/or created an intimidating, hostile, and offensive working environment. 34. As a result of the aforesaid unlawful conduct, Plaintiff has sustained lost wages, has been deprived of the benefits of gainful employment into the future, has sustained significant emotional distress damages, has suffered a diminution in her earning capacity, and has incurred or will incur significant attorneys’ fees and costs in order to secure her rights. COUNT SEVEN: COMMON LAW ASSAULT AND BATTERY PLAINTIFF VS. WILLIAM C. MULLEN III 1. Paragraphs 1 through 32 of Count One are hereby repeated and re- alleged as Paragraphs 1 through 32 of this Count Seven as if fully set forth herein. 33. MULLEN’s conduct, as delineated hereinabove, constituted multiple instances of assault and battery upon the Plaintiff. 34. As a result of the aforesaid unlawful conduct, has sustained significant emotional distress damages, has suffered a diminution in her earning capacity, and has sustained other losses and damages to her detriment. 12COUNT EIGHT: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS PLAINTIFF VS. WILLIAM C. MULLEN III de Paragraphs 1 through 32 of Count One are hereby repeated and re- alleged as Paragraphs 1 through 32 of this Count Eight as if fully set forth herein. 33. | MULLEN negligently inflicted emotional distress upon the Plaintiff by virtue of the foregoing conduct. 34. MULLEN’s conduct created an unreasonable risk of causing Plaintiff emotional distress. 35. Plaintiff's emotional distress was foreseeable to MULLEN, and his conduct was of such a nature that he was aware or should have been aware that there was risk of illness or bodily harm to Plaintiff. 36. As a result of the MULLEN’s unlawful conduct, Plaintiff has sustained severe emotional distress damages, has suffered a diminution in her earning capacity, and has sustained other losses and damages to her detriment. COUNT NINE: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS PLAINTIFF VS. WILLIAM C. MULLEN III le Paragraphs 1 through 32 of Count One are hereby repeated and re- alleged as Paragraphs 1 through 32 of this Count Nine as if fully set forth herein. 33. MULLEN intentionally inflicted emotional distress upon the Plaintiff by virtue of the foregoing conduct. 34. | MULLEN’s either intended to inflict emotional distress upon the Plaintiff or knew or should have known that emotional distress was the likely result of his conduct. 35: MULLEN’s conduct, as aforesaid, was extreme and outrageous. 1336. Plaintiff's emotional distress was foreseeable to MULLEN, and his conduct was of such a nature that he was aware or should have been aware that there was risk of illness or bodily harm to Plaintiff. 37. As a result of the MULLEN’s unlawful conduct, Plaintiff has sustained severe emotional distress damages, has suffered a diminution in her earning capacity, and has sustained other losses and damages to her detriment. PLAINTIFF, ANGELINA ANDREOLI 364 Franklin Avenue Hartford, CT 06114 Tel: (860) 296-3457 Fax: (860) 296-0676 Juris No.: 419987 Email: mparadisi@cicchielloesq.com 14RETURN DATE: JUNE 18, 2019 : SUPERIOR COURT ANGELINA ANDREOLI : J.D. OF NEW HAVEN Vs. : AT NEW HAVEN COMCAST CABLE COMMUNICATIONS MANAGEMENT, LLC,CREDICO (USA) LLC, AND WILLIAM C. MULLEN III : MAY 15, 2019 PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for the following relief: Money damages; Costs of this Action; Attorneys fees pursuant to Conn. Gen. Stat. § 46a-104; Punitive damages as to Count Nine; and All other awardable relief. gPon> PLAINTIFF, ANGELINA ANDREOLI chiello & Cicchiello, LLP 364 Franklin Avenue Hartford, CT 06114 Tel: (860) 296-3457 Fax: (860) 296-0676 Juris No.: 419987 Email: mparadisi@cicchielloesg.com 15RETURN DATE: JUNE 18, 2019 : SUPERIOR COURT ANGELINA ANDREOLI J.D. OF NEW HAVEN Vs. : AT NEW HAVEN COMCAST CABLE COMMUNICATIONS MANAGEMENT, LLC,CREDICO (USA) LLC, AND WILLIAM C. MULLEN Ill | MAY 15, 2019 STATEMENT OF AMOUNT IN DEMAND The amount in demand is in excess of $15,000.00, exclusive of interest and costs. PLAINTIFF, ANGELINA ANDREOLI . Paradisi Cicchiello & Cicchiello, LLP 364 Franklin Avenue Hartford, CT 06114 Tel: (860) 296-3457 Fax: (860) 296-0676 Juris No.: 419987 Email: mparadisi@cicchielloesg.com 16EXHIBIT ASTATE OF CONNECTICUT COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES Angelina Andreoli COMPLAINANT CHRO No. 1930169 vs. EEOC No. 16A201900087 Comcast of Connecticut Inc. RESPONDENT RELEASE OF JURISDICTION The Commission on Human Rights and Opportunities hereby releases its jurisdiction over the above- identified complaint. The Complainant is authorized to commence a civil action in accordance with CONN. GEN. STAT. § 46a-100 against the Respondent in the Superior Court for the judicial district in which the discriminatory practice is alleged to have occurred, in which the Respondent transacts business or in which the Complainant resides. If this action involves a state agency or Official, it nay be brought in the Superior Court for the judicial district of Hartford. A copy of any civil action brought pursuant to this release must be served on the Commission at ROJ@ct.gov or at 450 Columbus Blvd., Suite 2, Hartford, CT 06103 at the same time all other parties are served. Electronic service is preferred. THE COMMISSION MUST BE SERVED BECAUSE IT HAS A RIGHT TO INTERVENE IN ANY ACTION BASED ON A RELEASE OF JURISDICTION PURSUANT TO CONN. GEN. STAT. § 46a-103._ The Complainant must bring an action in Superior Court within 90 days of receipt of this release and within two years of the date of filing the complaint with the Commission unless circumstances tolling the statute of limitations are present. Saenger Ago DATE: March 21, 2019 Tanya A. Hughes, Executive Director Service: Complainant: mparadisi@cicchielloesg.com Complainant's attorney: mparadisi@cicchielloesg.com Respondent: Comcast of Connecticut Inc Respondent's attorney: jfritz@fisherphillips.comSTATE OF CONNECTICUT COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES Angelina Andreoli COMPLAINANT CHRO No. 1930401 vs. EEOC No. 16A201900484 Credico (USA) RESPONDENT RELEASE OF JURISDICTION The Commission on Human Rights and Opportunities hereby releases its jurisdiction over the above- identified complaint. The Complainant is authorized to commence a civil action in accordance with CONN. GEN. STAT. § 46a-100 against the Respondent in the Superior Court for the judicial district in which the discriminatory practice is alleged to have occurred, in which the Respondent transacts business or in which the Complainant resides. If this action involves a state agency or Official, it may be brought in the Superior Court for the judicial district of Hartford. A copy of any civil action brought pursuant to this release must be served on the Commission at ROJ@ct.gov or at 450 Columbus Blvd., Suite 2, Hartford, CT 06103 at the same time all other parties are served. Electronic service is preferred. THE COMMISSION MUST BE SERVED BECAUSE IT HAS A RIGHT TO INTERVENE IN ANY ACTION BASED ON A RELEASE OF JURISDICTION PURSUANT TO CONN. GEN. STAT. § 46a-103._ The Complainant must bring an action in Superior Court within 90 days of receipt of this release and within two years of the date of filing the complaint with the Commission unless circumstances tolling the statute of limitations are present. = Junge ADM ig Pos DATE: March 21, 2019 Tanya A. Hughes, Executive Director Service: Complainant: mparadisi@cicchielloesq.com Complainant's attorney: mparadisi@cicchielloesg.com Respondent: Credico (US) Respondent's attorney: acalifano@seyfarth.comSTATE OF CONNECTICUT COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES Angelina Andreoli COMPLAINANT CHRO No. 1930428 vs. EEOC No. N/A William Mullen RESPONDENT RELEASE OF JURISDICTION The Commission on Human Rights and Opportunities hereby releases its jurisdiction over the above- identified complaint. The Complainant is authorized to commence a civil action in accordance with CONN. GEN. STAT. § 46a-100 against the Respondent in the Superior Court for the judicial district in which the discriminatory practice is alleged to have occurred, in which the Respondent transacts business or in which the Complainant resides. If this action involves a state agency or Official, it may be brought in the Superior Court for the judicial district of Hartford. A copy of any civil action brought pursuant to this release must be served on the Commission at ROJ@ct.gov or at 450 Columbus Blvd., Suite 2, Hartford, CT 06103 at the same time all other parties are served. Electronic service is preferred. THE COMMISSION MUST BE SERVED BECAUSE IT HAS A RIGHT TO INTERVENE IN ANY ACTION BASED ON A RELEASE OF JURISDICTION PURSUANT TO CONN. GEN. STAT. § 46a-103._ The Complainant must bring an action in Superior Court within 90 days of receipt of this release and within two years of the date of filing the complaint with the Commission unless circumstances tolling the statute of limitations are present. —Sange AWM gA as DATE: March 21, 2019 Tanya A. Hughes, Executive Director Service: Complainant: mparadisi@cicchielloesq.com Complainant's attorney: mparadisi@cicchielloesq.com Respondent: William Mullen — via regular mail Respondent's attorney: n/a