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Law Offices of
Rob Serafinowicz, LLC52 Holmes Avenue
Waterbury, CT 06702
WWW.RAS-LAW.COM (203) [email protected] Mobile (203)
206-9907
Fax (203) 528-4302
________________________________________________________________________
Fran Teodosio, Esquire
Winnick, Vine, Welch, Teodosio and Blake LLC
375 Bridgeport AvenueShelton, CT 06484
October 8, 2010
VIA FACSIMILE (203) 925-3003 (3 pages)
RE: Mustafa Salahuddin
Dear Attorney Teodosio:
In response to your letter dated October 7, 2010. I must say I
am perplexed. It
has never been lost on me that you considered my client seeing
Dr. Adamakos, who you
claim is not a doctor, despite him possessing the requisite
credentials, as some sort of
ace in the hole. Unfortunately for you my client had been
assessed by a licensedpsychiatrist, Dr. S. David Bernstein, some
time ago. As you have never requested any
information regarding this, or even asked me about it, much like
you have not contacted
the Citys outside counsel regarding the settlement of this
matter and much like youignored my request that you, on the Citys
behalf, schedule an independent medical
examination of my client, I did not forward it along. In
addition, I continued to forward
you information from Dr. Adamakos because that was who the
Ansonia PoliceDepartment suggested my client see regarding this
matter and I assumed the doctor
recommended by the Ansonia Police Departments Officer Assistance
Program would be
sufficient for you. If I am to understand your position
correctly you are stating themedical professionals the department
refers its officers to are somehow substandard. I
would then suggest you contact the relevant parties within the
department to compile alist which meets your standards. As these
doctors perform an important, if not essentialfunction, that is
treating police officers, one would assume they possess the
requisite
qualifications to do this, which is why the department
recommends them to its officers.
You are also fully aware that this situation is not one
appropriate for theWorkmans Compensation Forum. While it may be in
the best interest of the City to
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attempt to handle the matter there, as this venue does not allow
recovery for much of the
actions complained of, it is simply not the forum to litigate
such issues.
As mentioned above you have never contacted me regarding the
scheduling of an
independent medical examination of my client despite my
specifically telling you when
he was available. If I understand your position, you doubt Dr.
Adamakoss credentialsyet you have made no attempt to remedy this
concern with an independent medical
examination by a doctor of your own choosing, which my client
has been ready willing
and able to attend and participate in. Instead you bring this
matter up to a member of themedia who immediately shared it with
me, and only bring it up to me directly in your
letter dated October 7, 2010. It is mind boggling that after
being informed of my clients
condition, by the doctor the department had referred him to, the
department is refusing to
even make an attempt at determining if he is fit for duty at
this time. One would thinkthat when a department approved doctor
states an officer is dealing with too much stress,
that same department would, at the bare minimum, attempt to
investigate the extent of the
stress. Instead the department has decided to proceed with its
original intent in bringing
the false criminal allegation, and is attempting to begin
termination proceedings againstmy client.
As stated before my client is suffering from Post Traumatic
Stress Disorder which
is the direct result of his being accused of stealing a garden
hose which was found within
the department prior to the criminal investigation being
commenced, and being forced to
stand trial for a crime he did not commit. For the better part
of two years he was forcedto live with uncertainty about his future
and then when the matter was finally concluded,
Police Commissioner Amico said in open session that my client
was a thief. The
department created a hostile work environment and when the
matter finally came to aclose the highest governing body within the
department decided to weigh in with an
opinion that only worsened the situation. Rather than just
letting the situation end
Commissioner Amico felt the need to yell at a taxpaying citizen
and then have himremoved from a public meeting because he had the
audacity to ask the board a simple
question, and then he referred to my client as a thief. My
client did not create this
situation, the Ansonia Police Department did and they are still
refusing to accept anyresponsibility and are refusing to take even
one measure to attempt to rectify it.
As to your trying to pull the proverbial fast one by scheduling
a hearing with
less than one weeks notice, I am not going to stand for that.
The hearing can either berescheduled with sufficient time to
prepare or this action will become just another means
for my client to recover upon the commencement of a civil
lawsuit. This complete
disregard of my clients right to have sufficient notice of a
hearing will simply becomethe basis for yet another violation of my
clients rights of due process that can be
litigated. I request this hearing be postponed one month for
purposes of preparing to
prevent evidence and to obtain the transcripts of the testimony
of Chief Hale, and others,given in the criminal proceeding so it
may be used at this hearing. I will also make
additional copies so any interested taxpayers may read it.
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This matter can be dealt with amicably through the proper
channels, or it can
become another situation where the taxpayers money is spent
unnecessarily.
In addition, to save everyone some time and effort I suggest you
contact Chief
Kevin Hale who, as of late, he has been the sole voice of reason
on the part of the City of
Ansonia, so he can tell you that he long ago authorized my
client to hold a job in additionto his police duties. This issue
was addressed in the internal affairs investigation
conducted by the Connecticut State Police in which all charges
levied against my client
were unsubstantiated. I fail to see how you can justify the
expense to the taxpayer ofinvestigating an issue in search of an
answer that you have had since February of this
year.
Finally, considering my client has a pending CHRO complaint
which complains
of the actions of both Robert Goldsen and Nicholas Amico, and my
client will becommencing a civil action against both individuals as
well as the city in the coming
months, it is only appropriate, and I specifically request they
both recuse themselves from
anything having do to with this matter. One aspect of this claim
is Commissioner Amico
referring to my client as a thief and then trying to prevent the
recording of this incidentfrom being disseminated to the public. If
anyone has trouble recalling this incident I have
a copy of the tape in my possession and will be happy to share
it. Again, if theseindividuals refrain from recusing themselves any
claim for wrongful termination becomes
stronger so proceed as you wish.
Very Truly Yours,
Rob Serafinowicz, Esquire
