State of Connecticut Commission on Human

Rights and Opportunities

AFFIDAVIT OF ILLEGAL DISCRIMINATORY PRACTICE

1. I have been retaliated against for my previous complaint of illegal

discriminatory practice which I filed at the State of Connecticut
Commission on Human Rights and Opportunities (CHRO) against the
City of Hartford and the Hartford Police Department. I have been
subjected to a Hostile Work Environment as part of my retaliation.

2. The Respondent is the City of Hartford, whose business address is 550

Main Street, Hartford, CT 06103 and the Hartford Police Department. I
am an employee of the Respondent. At all relevant times, I was
employed by the Respondent City of Hartford. I currently serve in the
capacity of Lieutenant with the Hartford Police Department.

3. The Respondent employs at least 15 persons.

4. On or about May 29, 2018, I reported an incident of sexual

harassment against a subordinate of mine at the time, by the
name of Kelly Baerga. I reported this incidence of sexual
harassment to Chief Rosado and Assistant Chief Medina. On
this same date right after I filed this sexual harassment
complaint on behalf of my subordinate, Kelly Baerga, I was
removed from my position as the Recruitment Commander and
subsequently relieved of my office, my company vehicle, and
my cellular phone. I was never advised of any performance
issues, pending disciplinary actions, or offered any other
rationale regarding my removal. I was also never provided
with any paperwork indicating that this was an INVOLUNTARY
transfer.

5. When I was removed from my position by Administration, the

sexual harasser that I reported, continued to work with Kelly
Baerga, and he continued to attend training sessions with her
even after he was finally removed from working directly with
her.
6. The victim, Kelly Baerga, was then moved to a desk in the
hallway outside of the Chief’s complex where the sexual
harasser had full access to her.

7. In or around the week of November 20, 2019, the Hartford

Police Department posted a position announcement for Vice-
Intelligence-Narcotics Division Commander. I drafted a
memorandum of interest, a Request for Reassignment, and a
Resume and submitted it to Chief David Rosado. My letter
was ignored.

8. I participated in the interview process for the Vice-Intelligence-

Narcotics Division Commander position. I was the only
Black/African-American scheduled on November 21, 2019,
which also served as the deadline for the application process.
After the conclusion of the interviews, the position remained
unfilled for approximately three additional months.

9. Regarding the Vice-Intelligence-Narcotics position, I composed

a second memorandum dated December 8, 2018, addressed
to the Human Resources Director Cherese Chery, indicating
my continued interest in the Vice-Intelligence-Narcotics
Division Commander position. I also requested an
investigation into the failure to select a commander for this
unit. HR never contacted me with a follow up to the concerns
that I voiced, and I found out later that the position was given
to a probationary Sergeant who did not even apply for the
position.

10. On or about December 4, 2018, there was an officer-involved

shooting. I was the only Black/African-American Commander
on the scene. At the scene, Assistant Chief (AC) Medina, one
of the individuals that I reported the sexual harassment claim
to, loudly and disrespectfully berated me in public as well as in
the presence of subordinates. This unprecedented outburst on
the part of AC Medina, served the purpose of inciting,
humiliating and ridiculing me in the presence of my colleagues
and other witnesses. Further, AC Medina made no attempt to
sensibly communicate with me in a critical work-related

2
 situation, exacerbating feelings of fear, panic and anxiety
amongst the rank and file.

11. AC Medina then ordered Deputy Chief (DC) Joseph Buyak to

obtain a written chronological account of my actions on the
night in question. I met with and reviewed my actions with DC
Buyak and satisfied his expectations.

12. Assistant Chief (AC) Medina’s tumultuous behavior continued

at the hospital where injured officers were present, as well as
their families. AC Medina’s actions alarmed officers, families
of the involved officers, and hospital staff.

13. On or about December 19, 2018, DC Buyak retired. Assistant

Chief Medina immediately ordered Captain Gabriel Laureano
to reinvestigate the incident in question at the time of Medina’s
outburst. I know of no White or Hispanic commander who has
ever been publicly berated in this manner, and then asked to
provide a written synopsis of his or her actions, or who had a
closed incident revisited.

14. On or about December 19, 2018, Deputy Chief Joseph Buyak

retired from the Hartford Police Department, leaving a vacancy
in the Chief's complex. The administration has refused to
appoint me to the open Chief's position even though the
Department is under a federal consent decree to bring the
hiring demographics of minorities and women into line with the
court-imposed numbers. (Cintron v. Vaughn) and PA 15-4.

15. On or about December 24, 2018, I filed a complaint with the

City of Hartford Human Resources Department relative to a
Hostile and Harassing Work Environment.

16. In or around January 2019 I filed a civil rights complaint with

the State of Connecticut Commission on Human Rights and
Opportunities (CHRO), and the U.S. Equal Employment
Opportunity Commission (EEOC) in Boston, Massachusetts.

17. On or about February 25, 2019, Lieutenant William Rea, a

Caucasian male, who is a probationary Lieutenant who did not

3
 even apply for the position of Vice-Intelligence-Narcotics
Division Commander, or partake in the interview process, was
given the job.

18. On or about Tuesday March 5, 2019 I was attending FBI-

LEEDA, a continuing education provider for police leaders
which is "designed to advance the science and art of law
enforcement leadership and promote the exchange of
information to improve law enforcement management practices
through, training, education, and networking among police
professionals across the United States and beyond."

19. Assistant Chief Jason Thody arrived at my training site in

Cheshire, Connecticut, during my lunch period and parked his
car adjacent to the exit doors, to impede me from leaving for
lunch. He then loudly called my name in front of my
classmates, before ordering me to abbreviate my lunch period
and to report back for an Internal Affairs investigation with
Internal Affairs Commander Kevin O'Brien.

20. This order was extremely embarrassing and humiliating as the

class had approximately 38 law enforcement leaders
throughout the New England area, and I was the only African-
American in the training. I was also the only person who was
singled out for an Internal Affairs Investigation in the middle of
my FBI training. This was extremely humiliating, and ironically,
I was NOT the subject of the Internal Affairs Investigation.

21. Immediately before I was released to go back to class, I was

read a statement by Assistant Chief Thody, which stated that I
was to maintain confidentiality throughout this investigation,
and that I was to discuss this investigation with no one. This
meant that every one of the participants in the training, who
saw me walked out by known investigators, along with the
Union President, and my Attorney, would not be able to have
any valid explanation as to the purpose of the investigation,
and the fact that I was not even the SUBJECT of the
investigation.

4
22. My classmates were afforded 1-½ hours for lunch to provide
networking opportunities and to allow us to find nourishment in
an unfamiliar area. I had my lunch hour cut to thirty minutes, so
that I could be interviewed as part of an internal affairs
investigation at an FBI Training in Cheshire, Connecticut, in the
presence of my colleagues, and at least seven members of the
Hartford Police Department.

23. I was extremely humiliated and embarrassed in front of this

group of candidates, many of whom I did not know, from
around the State of Connecticut and throughout the region.
This type of treatment served to almost criminalize me in the
presence of a statewide contingency of public safety leaders
throughout the state of Connecticut. I was further humiliated
when I had to return to the training almost three hours late, just
before they broke for the end of the day, following a lengthy
internal affairs investigation.

24. In a recent Internal Affairs Investigation, an attempt was made

by Administration, to embarrass me. Tiffany Wilson confronted
me with a charge that I paid her to do homework for me in a
statistics course. This charge had had no merit, and it only
served to humiliate and embarrass me among my colleagues.

25. Officer Wilson’s claims made to Internal Affairs, that I paid her
to do my homework in my statistics class, were false, and
trumped up, and designed to embarrass and humiliate me
before my colleagues. It was her claim that I had agreed to
pay her to do my homework for a statistics class. This was not
true, and none of the homework was graded in this class so
there was no need for me to pay her to do homework for me.
The entire course grade was based on how well we did on the
final examination. To pay her to do my homework would make
no sense, as it has nothing to do with my final grade, which
was a B+. Had I not completed my own assignments, and
done my own studying, there is no way that I could have
received such a high score on my final exam.

26. The Administration rewarded Officer Wilson for creating a false

document with false changes against me, by placing her in the

5
 Recruitment unit that I was removed from the day that I filed a
sexual harassment claim against Officer Rodney, on behalf of
Kelly Baerga.

27. I request that the Connecticut Commission on Human Rights

and Opportunities investigate my complaint of RETALIATION
based on my opposition to what I reasonably believed to be
discriminatory practices in the workplace, and to secure for me
the rights guaranteed under the laws of the State of
Connecticut, federal anti-discrimination laws, and the
Constitution of the United States, and to provide me with any
remedy to which I may be entitled.

28. I claim all of the above cited treatment is due to retaliation for
my engaging in protected activity, in violation of Conn. Gen
Stat. Sec. 46a-58(a), 46a-60(a)(1), and Title VII of the Civil
rights Act of 1964, as amended, 42, U.S.C. 2000 and the Civil
Rights Act of 1991.

6
 OATH

PAUL WEST, being duly sworn, on oath, states that he is the Complainant
herein; that he has read the foregoing complaint and knows the content thereof;
that the same is true of hIs own knowledge, except as to the matters herein
stated on information and belief and that as to these matters, he believes the
same to be true.

Dated at_____________________, Connecticut this _______day of March 2019.

________________________________
PAUL WEST-Complainant

Subscribed and sworn to before me on this_________day of March 2019.

________________________________________
Notary Public/Commissioner of the Superior Court

My Commission Expires__________________