STATE OF NEW YORK

COUNTY OF MONROE

TOWN OF GATES

JOHN R. PARRINELLO
Claimant,
-vs-

NOTICE OF CLAIM

THE TOWN OF GATES, MARK ASSINI, INDIVIDUALLY

AND AS SUPERVISOR OF THE TOWN OF GATES,
NEW YORK; JAMES VANBREDERODE, INDIVIDUALLY
AND AS POLICE CHIEF OF THE TOWN OF GATES, NEW
YORK; OFFICER J. COUGHLIN, INDIVIDUALLY AND AS
A POLICE OFFICER OF THE TOWN OF GATES, NEW
YORK; S.M.O'MARA, INDIVIDUALLY AND AS A
INVESTIGATOR WITHTHE TOWN OF GATES, NEW
YORK; SGT. GRIMM, INDIVIDUALLY AND AS A SGT.
OF THE TOWN OF GATES, NEW YORK
Respondents.

PLEASE TAKE NOTICE, that John R. Parrinello, claimant herein, makes claim
against the above-named respondents, and, in support thereof, claimant states:
1.

The name and post office address of the claimant is John R. Parrinello, 36

West Main Street, Suite 400, Rochester, New York 14614.

2.

The name and post office address of the claimant's attorney is Geiger and

Rothenberg, LLP, David Rothenberg, Esq., of Counsel, 45 Exchange Blvd., Suite 800,
Rochester, New York 14614.
3.

The nature of the claim includes, but is not limited to, conspiracy, false

arrest, malicious prosecution intentional and/or negligent infliction of mental distress;

slander, violation of claimant's Fourth, Fifth and Fourteen Amendments of the United
States Constitution,

Article 1 Section 12 of the New York State Constitution, 42 USC

1983, and 1988 and New York Civil Rights Law.

4.

The false arrest was a result of the negligent hiring, negligent training

and supervision of officers of the Town of Gates Police Department referred to above as
respondents, as well as a continuing conspiracy between Mark Assini, Chief
Vanbrederode,
5.

and others.
As a result of the conspiracy, negligent screening, hiring, training and

supervision of the Gates Police Officers by Supervisor Mark Assini, Gates Police Chief
James Vanbrederode,

claimant's rights under the 4th, 5th and 14thAmendments of the

United States Constitution and 42 U.S.C. 1983 and 1988, Article 1, Section 12 of the
New York State Constitution and N.Y. Civil Rights Law Section 8 were violated.
6.

The claimant's arose on August 20, 2015, when claimant was falsely

arrested pursuant to a continuing conspiracy between Mark Assini and Chief

Vandbrederode

and others and the action of the by members of the Town of Gates

Police Department, named herein. Subsequently Mark Assini, individually and as Gates
Town Supervisor slandered claimant when Assini was interviewed by WHEC TV and
Kimberly and Beck, 95.1 F.M.
7. The items of damage or injuries as a result of the conduct complained of
above includes but is not limited to public humiliation, emotional distress, mental
suffering, interference with claimant's law practice, punitive damages, and legal fees.
8. The amount of damages in this action exceeds limits of all New York State
Courts except the New York State Supreme Court.
WHEREFORE,

Claimant demands judgment against respondents in an amount

to be determined upon trial of this action, together with the costs and disbursements of
this action, punitive damages and legal fees.

Dated:

November 16,2015
Rochester, New York

State of New York)

County of Monroe)
I am the Claimant in the above-entitled action. I have read the foregoing Notice
of Claim and know the contents thereof. The contents are true to my knowledge except
the matters therein stated to be alleged up
. formation and
I,
and, as to those
matters, I believe them to be true.

Sworn to before me this

day of November, 2015.

I ~tl?

ili, St1~
N(Jary Public
GLORIA M. TRUDE
Notary Public, State of New York
No. 01TR4813941
Qualified in Wayne County
'0
Commission Expires May 31,

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