Yolanda D. Tyson v. The Town of Ramapo, Et Al.

Case 7:17-cv-04990 Document 1 Filed 07/03/17 Page 1 of 24
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
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YOLANDA D. TYSON Complaint
Jury Trial Demand

Plaintiff,
-against-
THE TOWN OF RAMAPO; CHRISTOPHER P. ST. LAWRENCE,

as Town Supervisor; YITZCHOK ULLMAN, as Councilman;
SAMUEL TRESS, as Councilman; BRENDEL CHARLES aka
BRENDEL LOGAN, as Councilwoman; PATRICK J. WITHERS; as
Councilman; BRAD R. WEIDEL, as Chief of Police, Police Department
Town of Ramapo; PETER F. BROWER, as Former Chief of Police, Police
Department Town of Ramapo and THOMAS COKELEY, as Captain,
Police Department Town of Ramapo, each sued individually and in their
official capacities as employees of THE TOWN OF RAMAPO
Defendants
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The plaintiff, YOLANDA D. TYSON by her attorney THE SANDERS FIRM, P.C., for
her complaint against defendants THE TOWN OF RAMAPO; CHRISTOPHER P. ST.
LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL CHARLES aka
BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F. BROWER and
THOMAS COKELEY respectfully set forth and allege that:
INTRODUCTION
This is an action filed on behalf of former employee plaintiff YOLANDA D. TYSON seeking
relief from defendants THE TOWN OF RAMAPO; CHRISTOPHER P. ST. LAWRENCE;
YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL CHARLES aka BRENDEL LOGAN;
PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F. BROWER and THOMAS COKELEY
alleging violations of her civil rights due to race and gender discrimination.
JURISDICTION AND VENUE

1. The jurisdiction of this Court is invoked pursuant to 18 U.S.C. 1965, 28 U.S.C.
1331, 1343 and 2202 to secure protection of and to redress deprivation of rights secured by:
a. the Civil Rights Act of 1871, 42 U.S.C. 1983, providing for the protection
of all persons in her civil rights and the redress of deprivation of rights under
color of law.
2. The unlawful employment practices, violations of plaintiffs civil rights complained
of herein were committed within the Southern District of New York.
3. The pendent jurisdiction of the federal district court is invoked with respect to the
plaintiffs claims under New York State Executive Law 296 because the entire action before the
court comprises one constitutional and civil rights case.
PROCEDURAL REQUIREMENTS
4. Plaintiff has filed suit with this Court within applicable statute of limitations.
5. Plaintiff is not required to exhaust any administrative procedures prior to suit under
the Civil Rights Act of 1871.
PLAINTIFF
6. Plaintiff YOLANDA D. TYSON is a female citizen over twenty-one (21) years of
age and a resident of Rockland County.
DEFENDANTS
7. Defendant THE TOWN OF RAMAPO is a municipal corporation operating under
state law and is plaintiffs former employer.
8. Defendant CHRISTOPHER P. ST. LAWRENCE, as Former Town Supervisor,
Town of Ramapo.
9. Defendant YITZCHOK ULLMAN, as Councilman, Town of Ramapo.
2
10. Defendant SAMUEL TRESS, as Councilman, as Town of Ramapo.
11. Defendant BRENDEL CHARLES aka BRENDEL LOGAN, as Councilwoman, as
Town of Ramapo.
12. Defendant PATRICK J. WITHERS, as Councilman, as Town of Ramapo.
13. Defendant BRAD R. WEIDEL, as Chief of Police, Police Department Town of
Ramapo.
14. Defendant PETER F. BROWER, as Former Chief of Police, Police Department
Town of Ramapo.
15. Defendant THOMAS COKELEY, as Captain of Police, Police Department Town of
Ramapo.
BACKGROUND
16. Plaintiff YOLANDA D. TYSON self identifies as an African-American Female,
and formerly employed as a police officer with defendant THE TOWN OF RAMAPO.
17. Plaintiff alleges prior to being appointed to the position of Police Officer, Town
of Ramapo, she was employed with the Police Department City of New York (NYPD).
18. Plaintiff alleges in or around January 2005, she was appointed to the position of
Police Officer, Police Department City of New York and assigned to the Recruit Training School
aka the Police Academy.
19. Plaintiff alleges after graduating from the Recruit Training School and working
several patrol assignments in the Bronx, she applied to work with defendant THE TOWN OF
RAMAPO for the enhanced salary and benefits.
20. Plaintiff alleges in or around February 2006, she was appointed to the position of
Police Officer, Police Department Town of Ramapo.
3
21. Plaintiff alleges the actions causing the injuries and damage to her property rights as
a civil servant and individual civil rights began in or around February 2006 and have continued to
this date.
22. Plaintiff alleges since February 2006, she and other colleagues of color, meaning
African-Americans have complained about race and gender discrimination to various police
administrators and union officials but their concerns were never addressed, met with retaliatory
actions and a hostile work environment.
23. Plaintiff alleges since February 2006, defendant THE TOWN OF RAMAPO
through its police management and town governing board openly and unfairly treats its officers
differently based upon their race and gender in the terms and conditions of employment
including salary, overtime, lateral movements, promotions, benefits policies and discipline.
24. Plaintiff alleges since February 2006, defendants THE TOWN OF RAMAPO;
CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL
CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.
BROWER and THOMAS COKELEY either received actual or constructive notice such practices
are occurring in the workplace and either condoned, acquiesced or promoted such discriminatory
animus and misconduct within the Police Department Town of Ramapo.
BROWER and THOMAS COKELEY received actual or constructive notice Caucasian officers
particularly males were treated more favorably with respect to awarding General Municipal Law
207-c benefits.
4
26. Plaintiff alleges since 2006, defendants THE TOWN OF RAMAPO;
BROWER and THOMAS COKELEY received actual or constructive notice the following
Caucasian officers particularly males received GML 207-c benefits without legal challenge: Neil
Sweeney (Male); Denise Dougherty (Female); Robert Chapman (Male); Mark Armstrong (Male);
Modestino Giusto (Male); Baile Glauber (Female); John Youngman (Male); James Curley (Male);
Danny Jacaruso (Male); Patrick Reynar (Male) and John Paolucci (Male).
Caucasian officers particularly males were never carried as Regular Sick: Neil Sweeney (Male);
Denise Dougherty (Female); Robert Chapman (Male); Mark Armstrong (Male); Modestino Giusto
(Male); Baile Glauber (Female); John Youngman (Male); James Curley (Male); Danny Jacaruso
(Male); Patrick Reynar (Male) and John Paolucci (Male).
Caucasian officers particularly males were afforded the opportunity to stay at home, some for
periods of more than ten (10) years without legal challenge: Neil Sweeney (Male); Denise
Dougherty (Female); Robert Chapman (Male); Mark Armstrong (Male); Modestino Giusto (Male);
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Baile Glauber (Female); John Youngman (Male); James Curley (Male); Danny Jacaruso (Male);
Patrick Reynar (Male) and John Paolucci (Male).
Caucasian officers particularly males received light duty assignments or reasonably
accommodated, some for periods of more than ten (10) years without legal challenge: Neil
Sweeney (Male); Denise Dougherty (Female); Robert Chapman (Male); Mark Armstrong (Male);
Modestino Giusto (Male); Baile Glauber (Female); John Youngman (Male); James Curley (Male);
Danny Jacaruso (Male); Patrick Reynar (Male) and John Paolucci (Male).
BROWER and THOMAS COKELEY received actual or constructive notice the aforementioned
Caucasian officers in Paragraph Nos.: 26 through 29, particularly males werent threatened with
termination or terminated under Civil Service Law Section 71.
BROWER and THOMAS COKELEY have never threatened with termination or terminated a
Caucasian officer particularly males under Civil Service Law Section 71.
32. Plaintiff alleges on or about January 31, 2012, she was involved in an on-duty
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accident with her department vehicle.
33. Plaintiff alleges on or about February 29, 2012, defendants THE TOWN OF
RAMAPO and PETER F. BROWER approved her application to receive benefits under GML 207-
c (r/arm, l/shoulder, r/hip, neck and back) for the January 31, 2012 on-duty accident with her
department vehicle.
34. Plaintiff alleges on or about March 16, 2012, she returned to work Full Duty
without restrictions although she DID NOT fully recover.
35. Plaintiff alleges on or about March 17, 2012, she left work due to neck pains and Dr.
Kraushaar recommended that she recover at home for approximately four (4) weeks.
36. Plaintiff alleges on or about April 4, 2012, defendants THE TOWN OF
RAMAPO and PETER F. BROWER reluctantly accommodated her with a light duty
administrative assignment.
37. Plaintiff alleges shortly thereafter, defendants THE TOWN OF RAMAPO and
PETER F. BROWER and their agents become increasingly hostile towards her.
38. Plaintiff alleges on or about October 2012, defendants THE TOWN OF RAMAPO;
PETER F. BROWER and BRAD R. WEIDEL ordered her to work and perform an administrative
assignment despite still receiving pains related to the January 31, 2012, on-duty accident with her
department vehicle.
39. Plaintiff alleges on or about January 29, 2013, she received an Interoffice
Memorandum from Administrative Lieutenant William Gravina outlining the conditions she would
need to fulfill to consolidate and re-acquire GML 207-c benefits.
40. Plaintiff alleges in or around February 2013, defendants THE TOWN OF
RAMAPO and PETER F. BROWER ordered her to report home, placed her on Regular Sick
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and her firearm was removed for safekeeping purposes.
41. Plaintiff alleges since February 2006, defendants THE TOWN OF RAMAPO and
PETER F. BROWER never treated similarly situated Caucasian officers particularly males in such a
manner.
42. Plaintiff alleges on or about April 24, 2013, she returns to Full Duty status
although she DID NOT fully recover from the January 31, 2012, on-duty accident with her
department vehicle.
43. Plaintiff alleges defendants THE TOWN OF RAMAPO and PETER F. BROWER
told her Dr. Gottlieb MUST write on her medical notes no medical restrictions or limitations.
44. Plaintiff alleges shortly thereafter, she reported sick again.
manner.
RAMAPO and PETER F. BROWER through Administrative Lieutenant William Gravina
advised her to report sick for duty each scheduled work day until further notice from the
department and to follow the restrictions in the duties of members on sick leave as specified in
General Order 705.3 (C).
manner.
RAMAPO and PETER F. BROWER through then Ramapo Patrolmans Benevolent Association
8
(PBA) President Dennis Procter, notified her that the department will be scheduling her for an
Independent Medical Examination (IME) to determine her duty status and ability to return to
work.
49. Plaintiff alleges in or around May 2013, she was subjected to an IME by
defendants THE TOWN OF RAMAPO and PETER F. BROWER and a determination was
made to return her to Full Duty status although she DID NOT fully recover from the January 31,
2012, on-duty accident with her department vehicle.
manner.
51. Plaintiff alleges on or about June 16, 2013, defendants THE TOWN OF RAMAPO
and PETER F. BROWER ordered her to return to work Full Duty although she DID NOT fully
recover from the January 31, 2012, on-duty accident with her department vehicle.
manner.
53. Plaintiff alleges on or about June 17, 2013, she returned to work Full Duty
although she DID NOT fully recover from the January 31, 2012, on-duty accident with her
department vehicle.
54. Plaintiff alleges on or June 18, 2013, she re-qualified with her department issued
service weapon and shotgun although she DID NOT fully recover from the January 31, 2012, on-
duty accident with her department vehicle.
9
manner.
56. Plaintiff alleges from June 2013 through October 2013 she called out sick numerous
times related to the January 31, 2012, on-duty accident with her department vehicle but, never
granted GML 207-c benefits as similarly situated Caucasian officers particularly males.
57. Plaintiff alleges on or about September 2013, she was injured taking an Emotionally
Disturbed Person (EDP) into police custody. She wanted the injuries to be treated as an aggravation
of the January 31, 2012, on-duty accident with her department vehicle.
58. Plaintiff alleges on or about October 29, 2013, she re-aggravated the neck and back
injuries she sustained in the January 31, 2012, on-duty department vehicle accident while getting
dressed in the locker room for her police duties.
59. Plaintiff alleges on or about November 5, 2013, defendants THE TOWN OF
RAMAPO and PETER F. BROWER DENIED her request for the October 29, 2013, injuries to be
treated as a re-aggravation related to the January 31, 2012, on-duty department vehicle accident for
approval of GML 207-c benefits.
60. Plaintiff alleges since February 2006, defendants THE TOWN OF RAMAPO
and/or PETER F. BROWER have never DENIED Caucasian officers requests for GML-207 c
benefits under similar circumstances.
61. Plaintiff alleges based upon defendants THE TOWN OF RAMAPO and PETER F.
BROWERS DENIAL of GML 207-c benefits, she was being carried as Regular Sick, under
house arrest and DENIED tax-free benefits unlike similarly situated Caucasian officers
particularly males.
62. Plaintiff alleges defendants THE TOWN OF RAMAPO and PETER F. BROWER
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ordered her to report to work every two (2) weeks although she DID NOT fully recover from the
January 31, 2012, on-duty accident with her department vehicle.
63. Plaintiff alleges on or about September 22, 2014, she received surgery to her lower
back.
64. Plaintiff alleges on or about October 2, 2014, defendants THE TOWN OF
RAMAPO and PETER F. BROWER ordered her to report to work within a few weeks after her
lower back surgery although she DID NOT fully recover from the January 31, 2012, on-duty
accident with her department vehicle.
65. Plaintiff alleges from October 2014 through March or April 2015, defendants THE
TOWN OF RAMAPO and PETER F. BROWER were classifying her as Regular Sick denying
her tax-free benefits under GML 207-c as similarly situated Caucasian officers particularly males.
66. Plaintiff alleges sometime between May 2015 and July 2015, she applied for a tax-
free GML 207-c Disability Retirement Pension.
67. Plaintiff alleges on or about December 16, 2015, the New York State Workers
Compensation Board approved her application for benefits, finding seventy (70%) percent loss in
wage earning capacity in the same employment.
68. Plaintiff alleges on or about January 29, 2016, she received her first letter from
defendants THE TOWN OF RAMAPO; CHRISTOPHER P. ST. LAWRENCE; YITZCHOK
ULLMAN; SAMUEL TRESS; BRENDEL CHARLES aka BRENDEL LOGAN and PATRICK J.
WITHERS threatening to terminate her employment on February 29, 2016, under Civil Service
Law Section 71.
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CHARLES aka BRENDEL LOGAN and PATRICK J. WITHERS have never sent such a
threatening letter to terminate a Caucasian officer particularly males employment under Civil
Service Law Section 71.
70. Plaintiff alleges on or about May 18, 2016, she received her second letter from
defendants THE TOWN OF RAMAPO; CHRISTOPHER P. ST. LAWRENCE; YITZCHOK
ULLMAN; SAMUEL TRESS; BRENDEL CHARLES aka BRENDEL LOGAN and PATRICK J.
WITHERS threatening to terminate her employment on June 24, 2016, under Civil Service Law
Section 71.
CHARLES aka BRENDEL LOGAN and PATRICK J. WITHERS have never sent such a
threatening letter to terminate a Caucasian officer particularly males employment under Civil
Service Law Section 71.
72. Plaintiff alleges on or about June 20, 2016, defendants THE TOWN OF
RAMAPO and BRAD R. WEIDEL ordered her to report to the stationhouse and turn over all
department issued equipment.
73. Plaintiff alleges on or about June 22, 2016, she turned over all department issued
equipment to defendants THE TOWN OF RAMAPO and BRAD R. WEIDEL.
74. Plaintiff alleges on or about June 24, 2016, defendants THE TOWN OF
RAMAPO; CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS;
BRENDEL CHARLES aka BRENDEL LOGAN and PATRICK J. WITHERS terminated her
employment after she repeatedly complained about the discriminatory animus and corruption within
the police department and governing board regarding the treatment of African-American officers in
12
the terms and conditions of employment.
75. Plaintiff alleges defendants THE TOWN OF RAMAPO; CHRISTOPHER P. ST.
THOMAS COKELEY did nothing to protect her employment rights.
76. Plaintiff alleges the conduct of defendants THE TOWN OF RAMAPO;
aka BRENDEL LOGAN; CHARLES; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.
BROWER and THOMAS COKELEY have interfered with her property rights as a civil servant and
her individual civil rights causing her emotional distress and substantial economic losses due to,
decreased take home pay, decreased pension valuation and inability to recover entitled tax free
benefits.
77. Plaintiff alleges the conduct of defendants THE TOWN OF RAMAPO;
BROWER and THOMAS COKELEY have caused her to incur thousands of dollars in legal costs
related to asserting violations of her property rights as a civil servant and her individual civil rights.
VIOLATIONS AND CLAIMS ALLEGED

COUNT I
FREEDOM OF SPEECH
IN VIOLATION OF
THE FIRST AMENDMENT OF THE UNITED STATES CONSTITUTION
78. Plaintiff re-alleges Paragraphs 1 through 77 and incorporates them by reference as
Paragraphs 1 through 77 of Count I of this Complaint.
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THOMAS COKELEY interfered with her right to freedom of speech and freedom of expression.
80. Plaintiff alleges she engaged in constitutionally protected speech and expression.
81. Plaintiff alleges she suffered retaliatory actions by defendants THE TOWN OF
RAMAPO; CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS;
BRENDEL CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL;
PETER F. BROWER and THOMAS COKELEY.
82. Plaintiff alleges the protected speech was a motivating factor in the retaliatory
actions.
THOMAS COKELEYS actions caused her to incur significant legal costs, emotional distress,
damage to her personal and professional reputation and loss of employment benefits.
COUNT II
RACE DISCRIMINATION
IN VIOLATION OF
THE CIVIL RIGHTS ACT OF 1871, 42 U.S.C. 1983
Paragraphs 1 through 83 of Count II of this Complaint.
85. Plaintiff alleges that defendants CHRISTOPHER P. ST. LAWRENCE;
acted in an outrageous and systematic pattern of discrimination, oppression, bad faith and cover-
14
up, directed at her and continuing from in or around February 2006 until this day.
86. Plaintiff alleges defendants CHRISTOPHER P. ST. LAWRENCE; YITZCHOK
ULLMAN; SAMUEL TRESS; BRENDEL CHARLES aka BRENDEL LOGAN; PATRICK J.
WITHERS; BRAD R. WEIDEL; PETER F. BROWER and THOMAS COKELEY caused her to
incur significant legal costs, emotional distress, damage to her personal and professional
reputation and loss of employment benefits.
COUNT III
GENDER DISCRIMINATION
IN VIOLATION OF
Paragraphs 1 through 86 of Count III of this Complaint.
acted in an outrageous and systematic pattern of discrimination, oppression, bad faith and cover-
up, directed at her and continuing from in or around February 2006 until this day.
COUNT IV
RETALIATION
IN VIOLATION OF
15
Paragraphs 1 through 89 of Count IV of this Complaint.
acted in an outrageous and systematic pattern of discrimination, retaliation, oppression, bad faith
and cover-up, directed at her and continuing from in or around February 2006 until this day.
COUNT V
HOSTILE WORK ENVIRONMENT
IN VIOLATION OF
Paragraphs 1 through 92 of Count V of this Complaint.
acted in an outrageous and systematic pattern of discrimination, hostility, oppression, bad faith
and cover-up, directed at her and continuing from in or around February 2006 until this day.
16
COUNT VI
MONELL CLAIM
IN VIOLATION OF
Paragraphs 1 through 95 of Count VI of this Complaint.
97. Plaintiff alleges defendant THE TOWN OF RAMAPO through its agents caused
her injuries.
98. Plaintiff alleges defendant THE TOWN OF RAMAPO actions of implementing
official and un-official policies of discrimination through its agents were under color of law.
99. Plaintiff alleges defendant THE TOWN OF RAMAPO through its agents
deprived her of constitutional and statutory rights.
100. Plaintiff alleges defendant THE TOWN OF RAMAPO through its agents actions
caused her injuries.
101. Plaintiff alleges defendant THE TOWN OF RAMAPO through its agents caused
her to sustain damages.
COUNT VII
NEGLIGENT HIRING
IN VIOLATION OF
102. Plaintiff re-alleges Paragraphs 1 through 101 and incorporates them by reference
as Paragraphs 1 through 101 of Count VII of this Complaint.
17
deprived her of constitutional and statutory rights by hiring defendants CHRISTOPHER P. ST.
THOMAS COKELEY.
decision to hire defendants CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN;
SAMUEL TRESS; BRENDEL CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS;
BRAD R. WEIDEL; PETER F. BROWER and THOMAS COKELEY reflects a deliberate
indifference to the risk that a violation of a constitutional or statutory right would follow.
105. Plaintiff alleges because defendant THE TOWN OF RAMAPO through its agents
decided to hire defendants CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN;
BRAD R. WEIDEL; PETER F. BROWER and THOMAS COKELEY she sustained constitutional
and statutory injuries.
COUNT VIII
FAILURE TO TRAIN
IN VIOLATION OF
as Paragraphs 1 through 105 of Count VIII of this Complaint.
107. Plaintiff alleges defendant THE TOWN OF RAMAPO through its agents knows
to a moral certainty that its employees will confront a given situation.
108. Plaintiff alleges the situation presents the employee with a difficult choice of the
sort either that training will make less difficult or that there is a history of employees
18
mishandling the situation.
109. Plaintiff alleges mishandling those situations will frequently cause the deprivation
of a citizens constitutional rights.
failure to train its employees regarding discrimination in the workplace she sustained
constitutional and statutory injuries.
COUNT IX
FAILURE TO SUPERVISE
IN VIOLATION OF
as Paragraphs 1 through 110 of Count IX of this Complaint.
112. Plaintiff alleges defendant THE TOWN OF RAMAPO through its agents knows
to a moral certainty that its employees will confront a given situation.
113. Plaintiff alleges the situation presents the employee with a difficult choice of the
sort either that training will make less difficult or that there is a history of employees
mishandling the situation.
114. Plaintiff alleges mishandling those situations will frequently cause the deprivation
of a citizens constitutional rights.
failure to train its employees she sustained constitutional and statutory injuries.
COUNT X
FAILURE TO DISCIPLINE
IN VIOLATION OF
19
as Paragraphs 1 through 115 of Count X of this Complaint.
deprived her of constitutional and statutory rights by failing to discipline defendants
BROWER and THOMAS COKELEY.
118. Plaintiff alleges defendant THE TOWN OF RAMAPO through its agents failure
to discipline defendants CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN;
BRAD R. WEIDEL; PETER F. BROWER and THOMAS COKELEY reflects a deliberate
indifference to the risk that a violation of a constitutional or statutory right would follow.
failure to discipline defendants CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN;
BRAD R. WEIDEL; PETER F. BROWER and THOMAS COKELEY she sustained constitutional
and statutory injuries.
COUNT XI
RACE DISCRIMINATION
IN VIOLATION OF
NEW YORK STATE EXECUTIVE LAW 296
as Paragraphs 1 through 119 of Count XI of this Complaint.
121. Plaintiff alleges that New York State Executive Law 296, makes it unlawful to
discriminate against any individual in the terms, conditions, or privileges of employment because
of their race.
20
122. Plaintiff alleges that defendants THE TOWN OF RAMAPO; CHRISTOPHER P.
ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL CHARLES aka
THOMAS COKELEY discriminated against her because of her race.
THOMAS COKELEYS violations caused her to incur significant legal costs, emotional distress,
COUNT XII
GENDER DISCRIMINATION
IN VIOLATION OF
as Paragraphs 1 through 123 of Count XII of this Complaint.
of their gender.
THOMAS COKELEY discriminated against her because of her gender.
21
COUNT XIII
RETALIATION
IN VIOLATION OF
as Paragraphs 1 through 127 of Count XIII of this Complaint.
of their race and/or gender.
130. Plaintiff alleges that the law also makes it unlawful to create an atmosphere where
retaliation is encouraged and/or tolerated.
THOMAS COKELEY engaged in various retaliatory actions against her based upon opposition
to race and gender discrimination.
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COUNT XIV
HOSTILE WORK ENVIRONMENT
IN VIOLATION OF
as Paragraphs 1 through 132 of Count XIV of this Complaint.
of their race and/or gender.
135. Plaintiff alleges that the law also makes it unlawful to create an atmosphere where
hostilities are encouraged and/or tolerated.
THOMAS COKELEY engaged in various hostile actions against her based upon opposition to
race and gender discrimination.
JURY TRIAL
138. Plaintiff demands a trial by jury of all issues in this action that are so triable.
PRAYER FOR RELIEF
Wherefore, plaintiff demands compensatory and punitive damages from defendant THE
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TOWN OF RAMAPO; CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN;
BRAD R. WEIDEL; PETER F. BROWER and THOMAS COKELEY for $75 million dollars plus
available statutory remedies, both legal and equitable, interests and costs.
Dated: June 29, 2017

New York, N.Y.
Respectfully submitted,
By: _____________s____________
Eric Sanders (ES0224)
THE SANDERS FIRM, P.C.

230 Park Avenue, Suite 1000
New York, NY 10169
(212) 808-6515 (Business Telephone)
(212) 729-3062 (Facsimile)
Website: http://www.thesandersfirmpc.com
24

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Case 7:17-cv-04990 Document 1 Filed 07/03/17 Page 1 of 24

UNITED STATES DISTRICT COURT

Jury Trial Demand

THE TOWN OF RAMAPO; CHRISTOPHER P. ST. LAWRENCE,

her complaint against defendants THE TOWN OF RAMAPO; CHRISTOPHER P. ST.

LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL CHARLES aka

BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F. BROWER and

THOMAS COKELEY respectfully set forth and allege that:

relief from defendants THE TOWN OF RAMAPO; CHRISTOPHER P. ST. LAWRENCE;

YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL CHARLES aka BRENDEL LOGAN;

PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F. BROWER and THOMAS COKELEY

JURISDICTION AND VENUE

1. The jurisdiction of this Court is invoked pursuant to 18 U.S.C. 1965, 28 U.S.C.

2. The unlawful employment practices, violations of plaintiffs civil rights complained

of herein were committed within the Southern District of New York.

court comprises one constitutional and civil rights case.

the Civil Rights Act of 1871.

6. Plaintiff YOLANDA D. TYSON is a female citizen over twenty-one (21) years of

age and a resident of Rockland County.

7. Defendant THE TOWN OF RAMAPO is a municipal corporation operating under

state law and is plaintiffs former employer.

8. Defendant CHRISTOPHER P. ST. LAWRENCE, as Former Town Supervisor,

9. Defendant YITZCHOK ULLMAN, as Councilman, Town of Ramapo.

10. Defendant SAMUEL TRESS, as Councilman, as Town of Ramapo.

11. Defendant BRENDEL CHARLES aka BRENDEL LOGAN, as Councilwoman, as

12. Defendant PATRICK J. WITHERS, as Councilman, as Town of Ramapo.

13. Defendant BRAD R. WEIDEL, as Chief of Police, Police Department Town of

14. Defendant PETER F. BROWER, as Former Chief of Police, Police Department

15. Defendant THOMAS COKELEY, as Captain of Police, Police Department Town of

16. Plaintiff YOLANDA D. TYSON self identifies as an African-American Female,

aka the Police Academy.

RAMAPO for the enhanced salary and benefits.

Police Officer, Police Department Town of Ramapo.

actions and a hostile work environment.

CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL

CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.

animus and misconduct within the Police Department Town of Ramapo.

CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL

CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.

26. Plaintiff alleges since 2006, defendants THE TOWN OF RAMAPO;

CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL

CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.

CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL

CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.

(Male); Patrick Reynar (Male) and John Paolucci (Male).

CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL

CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.

Patrick Reynar (Male) and John Paolucci (Male).

CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL

CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.

Caucasian officers particularly males received light duty assignments or reasonably

CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL

CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.

termination or terminated under Civil Service Law Section 71.

CHRISTOPHER P. ST. LAWRENCE; YITZCHOK ULLMAN; SAMUEL TRESS; BRENDEL

CHARLES aka BRENDEL LOGAN; PATRICK J. WITHERS; BRAD R. WEIDEL; PETER F.

accident with her department vehicle.

without restrictions although she DID NOT fully recover.

36. Plaintiff alleges on or about April 4, 2012, defendants THE TOWN OF

need to fulfill to consolidate and re-acquire GML 207-c benefits.

40. Plaintiff alleges in or around February 2013, defendants THE TOWN OF

and her firearm was removed for safekeeping purposes.

44. Plaintiff alleges shortly thereafter, she reported sick again.