820 Enfield Street
Enfield, Connecticut 06082
November 26, 2007
NOTICE OF INTENT TO COMMENCE CIVIL ACTION
In accordance with the laws of the State of Connecticut, including Conn. Gen. Stat. § 7-465, NOTICE is hereby given that Jack C. Mancuso together with his two minor children, Massimo Mancuso, and Vanessa Mancuso, intend to bring a civil action against the Town of Enfield, and its employees listed below, because of damage to person and property, and deprivation of civil rights guaranteed under the United States Constitution, the Connecticut Constitution, and the laws of the State of Connecticut, sustained as result of the harassment and intimidation perpetrated by the Mayor of Enfield in the event there proves to be a factual basis for such a claim. In addition the Claimant intends to bring a civil action based upon the possibly subsequent unlawful conduct of the Chief and/or members of the Enfield Police Department.
Date of Incident: On or around May 28, 2007
Time of Incident: Approximately 5:15 p.m.
Place of Incident:
40 Hazard Avenue
Enfield, CT 06082
Claim: At the above date, time, and place, the Mayor of Enfield, Patrick L. Tallarita, was in close proximity of Jack C. Mancuso and his two young children, all of whom were present at the above-listed location. At this time, he began shouting at them and making obscene gestures. Immediately thereafter, while they were unloading their groceries from the check out counter, Mr. Tallarita forced his way in closer physical proximity to the Mancusos, close to the check out counter, while continuing to shout and gesture in an aggressive and angry manner.
The content of Mr. Tallarita's screaming consisted of threats, including physical threats. Mr. Tallarita made it clear that his words and actions were in response to Mr. Mancuso's filing a complaint with the Public Integrity Unit of the Chief State's Attorneys' Office.
Shortly after this incident, upon information and belief, based upon information provided by others, the Chief of Police, Carl Sferrazza, and/or members of the Enfield Police Department may have gone to Shaw's store and demanded they produce all recordings of any security camera that might have recorded the incident. The claimant's hereby provide notice that they intend to take action to investigate the factual basis of this claim and to pursue legal action in the event there is a basis for pursuing such a claim.
Person Suffering Damage:
Jack C. Mancuso
Injuries: Personal injuries including but not limited to the following: emotional distress, anxiety, depression, humiliation, loss of enjoyment of life's activities, loss of reputation, post-traumatic stress syndrome, and fear for the safety of their family. Some of which injuries and concerns are permanent in nature.
Town of Enfield
Patrick L. Tallarita, Mayor
Carl Sferrazza, Chief of Police
Officer John Doe #1
Officer John Doe #2
Alleged Violations: Among other things, violations of the United States and Connecticut Constitutions, and violation of the laws of the State of Connecticut including assault, battery, negligence, intentional and negligent infliction of emotional distress.
Dated at Hartford, Connecticut this 26th day of November 2007.
A. Paul Spinella, Esq.
Spinella & Associates
One Lewis Street
Hartford, CT 06103
Juris No. 413617
JI Reports Notice To Sue Cocoa Puffs, Town, PD
Ex-mayor facing lawsuit threat over supermarket confrontation
By Anne Pallivathuckal
ENFIELD - Former Democratic Town Chairman Jack C. Mancuso has filed a notice of intent to sue the town, former Mayor Patrick L. Tallarita, and the Police Department over an incident in which he alleges that the former Democratic mayor verbally abused him at a supermarket last spring.
Mancuso said in the notice filed last week that while he and his two children were shopping at the Shaw's Supermarket on Hazard Avenue on May 28, Tallarita "began shouting at them and making obscene gestures" in an "aggressive and angry manner."
He said that Tallarita "made it clear" that he was responding to a complaint Mancuso had filed against him with the public integrity unit of the chief state attorney's office.
Mancuso had filed complaints with state and federal prosecutors over what he called "unfounded" zoning actions that the town had taken over parking at the Enfield
Montessori School. Mancuso, whose son and daughter attend the school, accused Tallarita of being involved in the zoning actions taken related to the issue.
Mancuso said in the notice that after the incident, "based upon information provided by others, the Chief of Police, Carl Sferrazza, and/or members of the Enfield Police Department may have gone to Shaw's store and demanded they produce all recordings of any security camera that might have recorded the incident."
Mancuso said that he intends to "investigate the factual basis of this claim and to pursue legal action in the event there is a basis for pursuing such a claim."
Sferrazza said today that no one from the Police Department went to Shaw's and made such a demand.
"I never did that nor directed another person to do that," Sferrazza said, calling the allegation "100 percent false."
No complaints related to the supermarket incident had been filed with the police, he said.
Mancuso said he and his children suffered "emotional distress, anxiety, depression, humiliation, loss of enjoyment of life's activities, loss of reputation, post-traumatic stress syndrome, and fear for the safety of their family" as a result of the incident.
Tallarita responded today to the allegations by questioning Mancuso's credibility. "I don't concern myself with Mr. Mancuso and his interpretations of the truth," he said.
"He should move on with his life and stop his troubling fascination with mine," added Tallarita, who announced a week after the Shaw's incident that he wouldn't seek re-election to the Town Council.