BOCHETTO & LENTZ, P.C. By: Bryan R. Lentz, Esquire [Peter R. Bryant, Esquire Attomey LD, Nos. 71383, 312328 1524 Locust Street Philadelphia, PA 19102 (215) 735-3900 (215) 735-2455 fax blentz@bochettoandlentz.com pbryant@bochettoandlentz.com JOHNFIORILL 75 Pequea Creek Road Conestoga, PA 17516 bow | PEQUEA TOWNSHIP 1028 Millwood Road Willow Street, PA 17584 jAnd CONESTOGA TOWNSHIP 3959 Main Street Conestoga, PA 17516 And | SOUTHERN REGIONAL POLICE COMMISSION 3284 Main Street Conestoga, PA 17516 CIVIL ACTION COMPLAINT ENTERED AND FILED PROTHONOTARY’S OFFICE LANCASTER, PA ***Electronically Filed*** Mar 20 2019 01:13PM ‘Adrianne Smith Attorneys for Plaintiffs CI-19-02575 COURT OF COMMON PLEAS LANCASTER COUNTY PENNSYLVANIA JURY TRIAL DEMAND} | AND NOW comes Plaintiff John Fiorill, by and through his undersigned counsel, Bochetto & Lentz, P.C. (“B&L”), and aver the following in support of his Civil Action Complaint against Defendants Southern Regional Police Commission, Pequea Township, and Conestoga Township, (collectively “Defendants” and avers as follows: ayis.25 ACHE 308 S\25 recatgt #161321 oslaolia AMSENTERED AND FILED PROTHONOTARY’S OFFICE LANCASTER, PA Electronically Filed*** Mar 20 2019 01:13PM 1. INTRODUCTION Adrianne Smith 1, This is a breach of contract action arising out of the intentional disparagement of Plaintiff Chief John Fiorill (“John”) by Cynthia Evans-Herr, Supervisor of Pequea Township, and Sohn Berry, Supervisor of Conestoga Township in their official capacities in clear breach of the Defendants promise not to disparage John. i Chief John Fiorill is the respected former police chief of Southern Regional Police CI-19-02575 Department in Conestoga and Pequea Townships. 3. Over the past forty years, John built a reputation as a premiere law enforcement officer. 4. He currently serves as Second Vice-President of the Pennsylvania Fraternal Order of Police (“PA FOP”). 5. 1n 2016, while Pequea and Conestoga Townships were experiencing purported financial straits, John agreed to step down as Police Chief in order to save the jobs of his officers. 6. Asaresult, John entered into an Agreement with Defendants to facilitate his retirement. |7. Pursuant to the Agreement, Defendants agreed to not make any disparaging i comments about John. Despite this, a year after the execution of the Agreement, Defendants — by and thoogh the elected official Bvan-er and Joba Berry — paraered with blogger named “Daddy Justice” to author a document that accused John of multiple criminal acts, including embezzlement, pension fraud, theft, sale of police weapons, bribery and criminal actions under color of law. 9. These statements were made intentionally without any good faith basis, and werePROTHONOTARY’S OFFICE LANCASTER, PA ***Electronically **% | Mar 20 2019 01:13PM false, malicious, disparaging, and in breach of Defendants’ obligations under the Adgieemensmith | ENTERED AND FILED 10. — Asaresult, Defendants have destroyed John’s hard-won reputation and caused him to experience substantial damages. 1 THE PARTIES '11.. Plaintiff Chief John Fiorll isan adult individual residing at 75 Pequea Creek Road, leeeaa 17516. CI-19-02575 112, Defendant Pequea Township is a municipality that may be served at 1028 Millwood Road, Willow Street, PA, 17584. 13, Defendant Conestoga Township is a municipality that may be served at 3959 Main Street, Conestogs, PA 17516 i 14, Defendant Southern Regional Police Commission may be served at 212 North Queen street, Lancaster, PA 17603. I. JURISDICTION AND VENUE 15, This Court has subject matter jurisdiction over this matter pursuant 10 42 PACA § 931(@ because the contract, sale and issues all arose in Pennsylvania. 16. Venue is proper in the Court of Common Pleas of Lancaster County under Rules 1006 and 2103 of the Pennsylvania Rules of Civil Procedure as Defendants are political subdivisions that are located in Lancaster County. Iv. THEKACTS A.| John Fiorill’s Forty Year Career In Law Enforcement. 17. Chief John Fiorill is a highly respected law enforcement professional in Lancaster County with over forty years experience as a member of the Lancaster County law enforcement community,