SUMMONS - CIVIL

JD-CV-1 Rev. 4-16 STATE OF CONNECTICUT ~

C.G.S. §~ 51-346, 51-347, 51-349, 51-350, 52-45a, SUPERIOR COURT
52-48, 52-259, P.B. §~ 3-1 through 3-21, 8-1, 10-13
wwwjud.ct.gov ~
See other side for instructions

E “X” if amount,
costs legal$2,500.
is less than interest or property in demand, not including interest and
“X” if amount, legal interest or property in demand, not including interest and
costs is $2,500 or more.
~ “X” if claiming other relief in addition to or in lieu of money or damages.

TO: Any proper officer; BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby commanded to make due and legal service of
this Summons and attached Complaint.
Address of court clerk where writ and other papers shall be filed (Number, street, town and zip code) Telephone number of clerk Return Date (Must be a Tuesday)
(C. G.S. ~ 51-346, 51-350) (with area code)
95 Washington Street, Hartford, CT 06106 ( 860 )548-2700 May
Month D~V
14 2 019
,
Year
~ Judicial District GA At (Town in which writ is returnable) (C.G.S. §~ 51-346, 51-349) Case type code (See list on page 2)
~ Housing Session Number: Hartford Major: T Minor: 90
For the Plaintiff(s) please enter the appearance of:
Name and address of attorney, law firm or plaintiff if self-represented (Number, street, town and zip code) Juris number (to be entered by attorney only)
Howard Kohn Sprague & Fitzgerald, 237 Buckingham Street, Hartford, CT 06106 028160
Telephone number (with area code) Signature of Plaintiff (If self-represented)
( 860) 525-3101
The attorney or law firm appearing for the plaintiff, or the plaintiff if Email address for delivery of papers under Section 10-13 (if agreed to)
self-represented, agrees to accept papers (service) electronically in ~ Yes E No •fstmhksflaw corn
this case under Section 10-13 of the Connecticut Practice Book.
Number of Plaintiffs: I Number of Defendants: 3 ~ Form JD-CV-2 attached for additional parties
Parties Name (Last, First, Middle Initial) and Address of Each party (Number; Street; P.O. Box; Town; State; Zip; Country, if not USA)
First Name: Mancini, Theodore and Sonia PPA Michael Mancini P-Of
Plaintiff Address:375 Ridgewood Road, West Hartford, CT 06107
Additional Name: P-02
Plaintiff Address:
First Name: Cheshire Academy D-01
Defendant Address: 10 Main Street, Cheshire, CT 06410
Additional Name: Anderson, Julie - Head of School, Cheshire Academy D-02
Defendant Address: 10 Main Street, Cheshire, CT 06410
Additional Name: Simon, Wesley - Dean, Cheshire Academy D-03
Defendant Address: 10 Main Street, Cheshire, CT 06410
Additional Name: D-04
Defendant Address:
Notice to Each Defendant
1. YOU ARE BEING SUED. This paper is a Summons in a lawsuit. The complaint attached to these papers states the claims that each plaintiff is making
against you in this lawsuit.
2. To be notified of further proceedings, you or your attorney must file a form called an ‘Appearance” with the clerk of the above-named Court at the above
Court address on or before the second day after the above Return Date. The Return Date is not a hearing date. You do not have to come to court on the
Return Date unless you receive a separate notice telling you to come to court.
3. If you or your attorney do not file a written “Appearance” form on time, a judgment may be entered against you by default. The “Appearance” form may be
obtained at the Court address above or at vrww.jud.ct.gov under “Court Forms.”
4. If you believe that you have insurance that may cover the claim that is being made against you in this lawsuit, you should immediately contact your
insurance representative. Other action you may have to take is described in the Connecticut Practice Book which may be found in a superior court law
library or on-line at www.jud.ct.gov under “Court Rules.”
5. If you have questions about the Summons and Complaint, you should talk to an attorney quickly. The Clerk of Court is not allowed to give advice on
legal questions.
Signed (Sign and ‘X” p rbox) Commissioner of the Name of Person Signing at Left Date signed
SupenorCourt I.
~ Assistant Clerk James F. Sullivan ~ 9//’~27f9
If this Sum is signed by a Clerk: For Court Use Only
a. The ing has been done so that the Plaintiff(s) will not be denied access to the courts. File Date
b. It is the responsibility of the Plaintiff(s) to see that service is made in the manner provided by law.
c. The Clerk is not permitted to give any legal advice in connection with any lawsuit.
d. The Clerk signing this Summons at the request of the Plaintiff(s) is not responsible in any way for any errors or omissions
in the Summons, any allegations contained in the Complaint, or the service of the Summons or Complaint.

I certify I have read and Signed ~ Date - , / Docket Number

understand the above: ~ ~ ‘~“f ‘3f_/7 ________________________
(Page 1 of2)
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RETURN DATE: MAY 14,2019 : SUPERIOR COURT

THEODORE AND SONIA : J.D. AT HARTFORD

MANCINI PPA MICHAEL MANCINI

VS. : AT HARTFORD

CHESHIRE ACADEMY
JULIE ANDERSON, HEAD OF SCHOOL
WESLEY SIMON, DEAN : APRIL 15, 2019

COMPLAINT
COUNT ONE: BREACH OF CONTRACT
1. Cheshire Academy (“the Academy”) is a college prepoatory school that is located in
Cheshire Connecticut. The defendant Julie Anderson is head of the school at the Academy. The
defendant Wesley Dean is a dean at the Academy.
2. Theodore and Sonia Mancini are the parents ofMichael Mancini who is a sophmore at
Cheshire Academy. The Mancini family lives in West Hartford, Connecticut.
3. In the July 2018, the Michael Mancini was recruited to attend and play football at the
Academy. The Mancinis met with football coach, Mr. Dykeman. The Mancinis asked Mr.
Dykeman for assurances that the Academy would tolerate diverse ideas held by its students and
was an all-inclusive community that would tolerate their conservative views.
4. Mr. Dykeman provided those assurances, and the Mancinis relied on those assurances. If
they were told otherwise they would not have sent Michael to the Academy. The Mancinis also
reviewed the Academy’s website, and looked at material provided by the Academy, where the
Academy promised to put “the unique needs of every student first.” The Academy promised
fairness and open mindedness of everyone’s beliefs and opinions. The Academy’s promise in its
mission statement is to develope confidence and critical thinking in its students. Moreover, the
Head of the School’s Welcome promises that “Cheshire Academy is a community in which
talented, dedicated faculty and staff motivate our students to stretch beyond their comfort zone.”
5. In reliance on those promises, the Mancinis enrolled Michael in the Academy.
6. In breach of all those promises, while in attendance at the Academy, Michael was
scrutinzed and tormented for his conservative views on subjects, views which he defended with
facts. He was ultimately told that he could not come back to the school next year because he was

HOWARD, KOHN SPRAGUE & FITZGERALD, LLP • ATTORNEYS-AT-LAW

237 BUCK~NGHAM STREET • P.O. BOX 261798. HARTFORD, CT 06126-1798. (860)525-3101 • JURIS NO. 28160
 (N

ot a good fit with the progressive culture that pervades the Academy. The Mancinis later
earned from Dean Wesley Simon’s facebook page that she is a “pro-choice, Obamacare
supporting climate change believing in minimum wage raising LGBT embracing immigration
eforming teacher supporting pay gap eliminating Democrat.”
7. Michael was thriving in his English class at the Academy. There was an incident,
however, in the English class where Michael made observations that were not intended to offend
or harass anyone. They were made in a class where the teacher, Emily Roller, repeatedly
encouraged a rich diversity of and openness to thoughts and opinions. She had observed that
Michael was “an asset to the class.” Michael made comments about sexual identity that were
general observations. In fact, his observations about what was acceptable at the time
Shakespeare wrote “Twelfth Night” were in fact true historically. There is a character in that
lay named Viola who cross dressed as a male (Cesario). Some in the class interpreted the play
as portraying trangenderism in a positive light. But Michael argued that that was not historically
accurate because up until the Twentieth Century that kind of behavior was frowned upon in
England. Michael was verbally attacked and screamed at by two students for making those
comments, for his opinion.
8. After Michael made these comments in English class, he had an earnest and private
discussion with his English teacher about how to steer clear of language that can upset others.
They turned to the topic addressed in Shakespeare’s Twelfth Night of homosexuality. Michael
said that he was fine with homosexuals being married but was opposed to any church or religious
organizations performing the ceremonies because it goes against their teachings or dogma. He
also spoke disapproving of pedophiles and he was concerned how they were trying to normalize
their outrageous behavior with acronyms like “MAPS” or minor attracted persons. He explained
that he did not want to see society trend in that direction.
9. On one Saturday, Michel participated in an mandatory Martin Luther King Workshop at
the Academy. Some of the other mandatory workshops were “White Privilege” and “Toxic
Masculinity.” Michael was told in that workshop by the teacher that whatever he said in that
class would stay in that class, saying this “is a safe space to express our ideas.” He trusted in that
promise, which was broken when his teacher reported him to the disciplinary authority for his
answer to the question the teacher had asked, “Tell us something that is obvious about your

HOWARD, KOHN SPRAGUE & FITZGERALD, LLP • ATTORNEYS-AT-LAW

237 BUCKINGHAM STREET • P.O. BOX 261798. HARTFORD, CT 06126-1798. (860)525-3101 • JURIS NO. 28160
 N

dentity.” Michael’s answer “Obviously I am black” was an attempt at making a joke, and
students both black and white in that workshop did laugh. Michael has apologized numerous
times for having made that comment. It was not directed at anyone nor designed to harass or
offend anyone. Again, that comment was made with a promise that it would not leave that room.
10. Because of Michael’s politically incorrect views, he was suspended for five days and
Cheshire Academy will not renew its contract with the Mancinis to have Michael attend Cheshire
Academy until he graduates in 2021.
11. One teacher at the Academy, Mr. Rogers, who was instrumental in getting Michael
suspended told Michael that one of the Federalist papers stated that if someone has a minority
view, that person has a “higher bar” to meet in proving oneself. Michael corrected Mr. Rogers,
stating that that Federalist paper made the opposite point, that in the democracy that is the United
States, the minority view point must be protected lest our country lapse into despotism.
12. The Academy’s promise of fairness and its own policies were breached in the way the
Academy imposed sanctions on Michael. There were supposed to be written reports of his
misconduct to give him notice of what to defend against. Michael was not allowed his English
eacher be his advocate. And the finding that he violated the Student and Family Handbook at
age 50 in “Failure to Thrive” is completely at odds with the meeting that was had with Mr.
ykeman and Ms. Simon where Mr. Dykeman stated that Michael was thriving and a thoughtful
and caring student who was kind to others and would volunteer to help others even when not
asked.
13. The Academy has breached the promises set forth in paragraphs 4 and 11.
14. As a result of those breaches, Michael suffers from irreparable harm.
COUNT TWO: NEGLIGENT MISREPRESENTATION
1. Paragraphs 1 through 13 of the Count One are hereby incorporated and set forth herein as
paragraphs 1 through 13 of Count Two.
14. The representations made in paragraph 4 were false and made negligently and such that
they caused harm and damage to Michael.
COUNT THREE: DEFAMATION
1. Paragraphs 1 through 13 of the Count One are hereby incorporated and set forth herein as
paragraphs 1 through 13 of Count Three.

HOWARD, KOHN SPRAGUE & FITZGERALD, LLP • ATTORNEYS-AT-LAW

237 BUCKINGHAM STREET • P.O. BOX 261798 • HARTFORD, CT 06126-1798. (860) 525-3101 • JURIS NO. 28160
14. The Academy falsely accused Michael of being a bigot, a racist, a misogynist, and a
xenophobe.
15. Such false accusations have damaged Michael’s reputation.

WHEREFORE, the plaintiffs claim:

1. Money damages;
2. A preliminary injunction and restraining order;
3. Any other relief of that in law and equity pertain.

PLAINTIFFS,

J~ ivan, Esq.
Kohn, Sprague & FitzGerald, LLP
Buckingham Street
P.O. Box 261798
Hartford, CT 06106
Juris Number: 28160
PH: 860-525-3101
FAX: 860-247-4201

HOWARD, KaHN SPRAGUE & FITZGERALD, LLP • ATTORNEYS-AT-LAW

237 BUCKINGHAM STREET • P.O. BOX 261798. HARTFORD, CT 06126-1798. (860) 525-3101 • JURIS NO. 28160
 4 n

RETURN DATE: MAY 14, 2019 SUPERIOR COURT

THEODORE AND SONIA J.D. AT HARTFORD

MANCINI PPA MICHAEL MANCINI

VS. AT HARTFORD

CHESHIRE ACADEMY
JULIE ANDERSON, HEAD OF SCHOOL
WESLEY SIMON, DEAN APRIL 15, 2019

STATEMENT OF AMOUNT IN DEMAND

The amount, legal interest, or property in demand is in excess of Fifteen Thousand

($15,000.00) Dollars or more, exclusive of interest and costs.

PLAINTIFFS,

By
J~ Sullivan, Esq.
Kohn, Sprague & FitzGerald, LLP
237 Buckingham Street
P.O. Box 261798
Hartford, CT 06106
Juris Number: 28160
PH: 860-525-3101
FAX: 860-247-4201

HOWARD, KOHN SPRAGUE & FITZGERALD, LLP • ATTORNEYS-AT-LAW

237 BUCKINGHAM STREET • P.O. BOX 261798. HARTFORD, CT 06126-1798. (860) 525-3101 • JURIS NO. 28160