Case 3:10-cv-00296-JBA Document 1 Filed 03/01/10 Page 1 of 5S UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT eS MARK VILLENEUVE v STATE OF CONNECTICUT, SALVATORE DIPIANO: IN HIS OFFICIAL CAPACITY, RICHARD FLORENTINE IN HIS OFFICIAL CAPACITY, : ATHARTFORD FRANCES DERA IN HER OFFICIAL : CAPACITY, PATRICIA KING IN HER : NO: OFFICIAL CAPACITY, : ‘THE MEMBERS OF THE WINDHAM : GRIEVANCE PANEL IN THEIR : FEBRUARY 25, 2010 OFICIAL CAPACITY, JUDGE JULIA AURIGEMMA IN HER OFFICIAL CAPACITY, RICHARD BLUMENTHAL IN HIS OFFICIAL CAPACITY, JUDGE BARBARA M. QUINN : IN HER OFFICIAL CAPACITY, ANDREW NORTON : IN HIS OFFICIAL CAPACITY, CT STATEWIDE GRIEVANCE COMMITTEE, MICHAEL FEDELE IN HIS OFFICIAL CAPACITY AND MARK DUBOIS IN HIS OFFICIAL CAPACITY COMPLAINT Mark Villeneuve, (Hereinafter, "Plaintiff’), hereby states and affirms for his Complaint against the State of Connecticut, (The Defendant’), Salvatore Dipiano, Head of the CT Grievance Committee, Richard Florentine, grievance counsel for the CT Statewide Grievance Committee, in his official capacity, Frances Mickelson Dera, Assistant Bar Counsel for the CT Statewide Grievance Committee, in her official capacity, Michael Bowler, Bar Counsel for the CT Statewide Grievance Committee, in his official capacity, Gregory Benoit, grievance counsel for the CT Statewide Grievance Committee, in his official capacity, Patricia King, disciplinary counsel, in her official capacity, Richard Blumenthal in his official capacity, Mark Dubois in his official capacity, Judge JuliaCase 3:10-cv-00296-JBA Document 1 Filed 03/01/10 Page 2 of 59 Aurigemma, judge of the Hartford Superior Court, in her official capacity, Andrew Norton, Chair of the Connecticut Commission on Human Rights and Opportunities, in his official capacity, Judge Barbara M. Quinn Chief Court Administrator, in her official capacity, the CT Statewide Grievance Committee and Michael Fedele, Lieutenant Governor, in his official capacity NATURE OF THE ACTION 1. This is an action brought pursuant to 42 U.S.C. §1983 alleging the deprivation of the due process of rights, privileges, and immunities secured by the Constitution and the laws of the United States and that the laws rules and regulations used are unconstitutionally broad and void for vagueness and that several statutes violate the state constitution. This action also alleges that state employees acting in their official capacity, acted in excess of their statutory authority and pursuant to unconstitutional rules and regulations and in violation of state law. This action also alleges that the Attorney General and the LT Governor failed to fulfil his duties to uphold Connecticut law and that Andrew Norton failed in his duties as chair of the Connecticut Commission on Human Rights and Opportunities. 2. By this action, Plaintiff seek the following relief for the violation of 42 U.S.C. §1983 related state claims and other state claims: That Connecticut Rules of Professional Conduct 8.4(3) and 8.4 (4) be struck down as unconstitutionally broad and void for vagueness, that the CT Statewide Grievance Committee be disbanded as an illegal organization which violates the separation of powers doctrine in article Il of the Connecticut State Constitution, That Connecticut General Statutes $51-80, 51-Case 3:10-cv-00296-JBA Document 1 Filed 03/01/10 Page 3 of 59 80a, 51-81, 51-84, 51-880, 51-90a, 51-90d, 51-90g, 51-90h, 51-91, 51-91a, be struck down as violative of Article 2 and Article 18 of the Connecticut Constitution That LT. Governor Michael Fedele, Attorney General Richard Blumenthal and ‘Andrew Norton, Chair of the Connecticut Commission on Human Rights and Opportunities, Conduct an investigation into the workings of the statewide grievance committee and its employees and assigns pursuant to CGSA §4-61dd and take all necessary and appropriate actions to remedy their corrupt and illegal actions. That Barbara M. Quinn conduct an investigation into the patterns and Practices of the Statewide Grievance Committee and take all appropriate actions to remedy their corrupt and illegal actions. JURISDICTION 3. This action is brought pursuant to 42 U.S.C. §1983 and the Fifth and Fourteenth Amendments to the United States Constitution. Jurisdiction is founded upon 28 U.S.C. §1332 and 28 U.S.C. §1343(a) and the principles of supplemental and pendant jurisdiction. PARTIES 4. Mark Villeneuve (‘Plaintiff’) is an attorney and resident of the State of Connecticut, 5. Connecticut (“CT”) is a duly formed state within the borders of the United States. 6. Salvatore Dipiano was at all times relevant to this complaint the head of the CT Statewide Grievance Committee. 7. Attorney Richard Florentine (“Florentine”) was at all times relevant to this complaint