LYNCH, TRAUS, KEEFE AND ERRANTE, P.-C. CY- 10~50 33347 © RETURN DATE: : SUPERIOR COURT JANE DOE and JOHIN DOB JUDICIAL DISTRICT OF NEW HAVEN | vs AT NEW HAVEN J] Aran sHutix : JUNE 11,2010 COMPLAINT COUNT ONE: (On behalf of Jane Doe for Reckless Battery): 1. tall times relevant to this action, the plaintiff, Jane Doe, was a resident of the State of Connecticut. 2. Atall times relevant to this action, the plaintiff, John Doe, was a resident of the State of Connecticut, 3. Atall times relevant to this action, plaintiffs, Jane and John Doe were the parents of a female minor child who will be referred to for the purposes of this action as Sally Doe, 4. Atall times relevant to this action, the defendant, Alan Shulik (“Shulik”) was a resident of the State of Connecticut and a PhD, who acted as a psychologist, psychotherapist and/or provided counseling services to individuals, couples and families, independently and/or through Bishop Street Counseling located at 147 Bishop Street, New Haven, Connecticut ("New Haven office”). 3. tall times relevant to this action, Shulik spoke to and/or met with patients f purpose of providing individual, marital and family counseling services, instruction and'guidange.:LYNCH, TRAUB, KEEFE ANO ERRANTE, F.C 6 Inoraround April or May of 2008, Jane Doe contacted Shulik by phone for the purpose of setting up marriage, family, and individual counseling with him for her and her husband, John Doe. 7. Atall times relevant hereto, Jane Doe was in a fragile and emotionally vulnerable state. 8. Onor around May 8, 2008, Jane Doe and John Doe traveled to Shulik’s New Haven office, where Shulik conducted a joint psychological interview and exam of both plaintiffs. Jane and John Doe recounted difficulties in their marriage and parenting issues they were struggling with due to a serious medical condition suffered by their child, Sally Doe, among other things. 9. ‘Thereafter, Shulik saw Jane and John Doe jointly for several sessions until determining that he needed to see Jane and John Dee individually in order to provide effective counseling services, 10, Between May of 2008 through July of 2008, Shulik conducted individual and joint counseling and therapy sessions with Jane and John Doe for the purpose of providing marriage, family, and individual counseling services. 11, During Shulik’s individual sessions with Jane Doe, Shulik would routinely refer to John, Doe in negative terms stating that he was a workaholic, unsupportive and words to the effect that Jane Doe could “do much better” and that she “deserved better.” 12, During Shulik’s individual sessions with John Doe, Shulik would advise John Doe that he needed to spend more alone time with his daughter, Sally Doe. This advice was dispensed as a ruse toPc No ERRANTE, A WYNCH, TRAUB, KEEFE © get John Doe and Jane Doe to spend more time apart so that Shulik could spend more time alone with Jane Doe and not have to worry that she had child-care issues. 13, At this same time, Shulik was encouraging plaintiff, Jane Doe to regularly contact him via text message, email and/or phone (collectively referred to as “contacts”), which Jane Doe proceed to do based on this recommendation. During these contacts, Shulik encouraged jane Doe to express her feelings, while he himself used these contacts to further denigrate John Doe. 14, Asa result of the frequent and manipulative counseling sessions and contacts between, || Shulik and Jane and John Doe, rather than acting to rehabilitate the Doe's relationship, Shulik instead exponentially increased the level of marital discord between the plaintiffs, while simultaneously increasing the level of dependence Jane Doe had on him. 15, tall relevant times, Jane Doe continued to be in a very fragile and emotional state. During his sessions with Shulik, John Doe repeatedly expressed his concern about Jane Doe's mental state, 16, During the course of counseling and his individual contacts with Jane Doe, Shulik began to progressively manipulate her. He would often tell her how special she was, how lucky any man would be to have her in his life, how beautiful she was and that he cared about her a great deal, among other things, || wocesesent ss encantai 5 LYNCH, TRAUB, KEEFE AND ERRANTE, F.C ° 17. The aforementioned increasingly intimate compliments in turn led to sexual advances on Jane Doe by Shulik during regular counseling sessions, Further, on or around June 26, 2008, during a scheduled counseling session Shulik began to kiss and fondle Jane Doe in his New Haven office. 18. A short time thereafter, Shulik drove Jane Doe to his house in Guilford, Connecticut where they engaged in sexual relations. 19. From that point forward, Shulik manipulated Jane Doe into engaging in clandestine sexual encounters at his house, his office, at hotels and other locations, which continued through August of 2009, 20. Atall relevant times, Shulik manipulated Jane Doe into believing that they were ina relationship and even told her that he wanted to marry her. The aforementioned relationship continued for several months through August of 2009, during which Shulik revealed private information to Jane Doe and encouraged her to leave her husband and seek a divorce. 21. Atall times relevant hereto, a psychologist/ patient relationship existed between Jane Doe and Shulik and John Doe and Shulik. 22, Atall times relevant hereto, Shulik continued to provide counseling services, instruction and guidance to both Jane and John Doe, 23. Asa result of Shulik’s reckless sexual battery, Jane Doe attempted suicide on January 18, 2010,LYNCH, TRAUB, KEEF ° 24. Asa result of Shulik’s reckless sexual battery, Jane Doe has suffered and continues to suffer debilitating and severe emotional injuries, some or all of which may be permanent in nature and which will require continued psychological counsel and care. 25. Asa result of Shulik’s reckless sexual battery, Jane Doe has incurred and will continue to incur expenses related to counseling, therapy and treatment, all to her loss and detriment. COUNTTWO: (On behalf of Jane Doe for Negligent Battery): 1-22, Paragraphs 1 through 22 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 22 of COUNT TWO as if more fully set forth herein. 23, Asa result of Shulik’s negligent sexual battery, Jane Doe attempted suicide on January 18, 2010. 24, Asa result of the negligence and carelessness of Shulik, Jane Doe has suffered and continues to suffer debilitating and severe emotional injuries, some or all of which may be permanent in nature and which will require continued psychological counsel and care, 25, Asa result of Shulik’s negligent sexual battery, Jane Doc has incurred and will continue to incur expenses related to counseling, therapy and treatment, all to her loss and detriment. COUNT THREE: (On behalf of Jane Doe for Reckless Infliction of Emotional Distress): 1-22. Paragraphs 1 through 22 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 22 of COUNT THREE as if more fully set forth herein,LyWeH, TRAUB, KEEFE 2 23. By his wrongful actions, Shulik recklessly inflicted, or knew or should have known that his wrongful actions were likely to cause, severe emotional distress on Jane Doe, 24, Shulik’s conduct was extreme, outrageous and beyond the bounds of decency. 25, Shulik’s wrongful actions caused Jane Doe severe emotional distress, COUNTFOUR: (On behalf of Jane Doe for Negligent Infliction of Emotional Distress): 1-22, Paragraphs 1 through 22 of COUNT ONE are hereby incorporated by reference and made Paragraphs 1 through 22 of COUNT FOUR as if more fully set forth herein. 23, Shulik should have realized that his negligent conduct as outlined in COUNT TWO, posed an unreasonable risk of causing Jane Doe emotional distress, and that such distress might result in illness. 24. Asa result of Shulik’s negligence, Jane Doe attempted suicide on January 18, 2010. 25. Asa result of Shulik's negligence, Jane Doe has suffered and continues to suffer debilitating and severe emotional injuries, some or all of which may be permanent in nature and which will require continued psychological counsel and care. 26. Asa result of Shulik’s negligence, Jane Doe has incurred and will continue to incur expenses related to counseling, therapy and treatment, all to her Joss and detriment,