Law Offices of

Rob Serafinowicz, LLC

52 Holmes Avenue
Waterbury, CT 06702

WWW.RAS-LAW.COM (203) 755-0267

RS9907@GMAIL.COM Mobile (203) 206-9907
Fax (203) 528-
4302
_______________________________________________________________________
_

Fran Teodosio, Esquire

Winnick, Vine, Welch, Teodosio and Blake LLC
375 Bridgeport Avenue
Shelton, CT 06484

October 8, 2010

VIA FACSIMILE (203) 925-3003 (3 pages)

RE: Mustafa Salahuddin

Dear Attorney Teodosio:

In response to your letter dated October 7, 2010. I must say I am perplexed. It

has never been lost on me that you considered my client seeing Dr. Adamakos, who you
claim is not a doctor, despite him possessing the requisite credentials, as some sort of
“ace in the hole”. Unfortunately for you my client had been assessed by a licensed
psychiatrist, Dr. S. David Bernstein, some time ago. As you have never requested any
information regarding this, or even asked me about it, much like you have not contacted
the City’s outside counsel regarding the settlement of this matter and much like you
ignored my request that you, on the City’s behalf, schedule an independent medical
examination of my client, I did not forward it along. In addition, I continued to forward
you information from Dr. Adamakos because that was who the Ansonia Police
Department suggested my client see regarding this matter and I assumed the doctor
recommended by the Ansonia Police Department’s Officer Assistance Program would be
sufficient for you. If I am to understand your position correctly you are stating the
medical professionals the department refers its officers to are somehow substandard. I
would then suggest you contact the relevant parties within the department to compile a
list which meets your standards. As these doctors perform an important, if not essential
function, that is treating police officers, one would assume they possess the requisite
qualifications to do this, which is why the department recommends them to its officers.

You are also fully aware that this situation is not one appropriate for the
Workman’s Compensation Forum. While it may be in the best interest of the City to
attempt to handle the matter there, as this venue does not allow recovery for much of the
actions complained of, it is simply not the forum to litigate such issues.

As mentioned above you have never contacted me regarding the scheduling of an

independent medical examination of my client despite my specifically telling you when
he was available. If I understand your position, you doubt Dr. Adamakos’s credentials
yet you have made no attempt to remedy this concern with an independent medical
examination by a doctor of your own choosing, which my client has been ready willing
and able to attend and participate in. Instead you bring this matter up to a member of the
media who immediately shared it with me, and only bring it up to me directly in your
letter dated October 7, 2010. It is mind boggling that after being informed of my client’s
condition, by the doctor the department had referred him to, the department is refusing to
even make an attempt at determining if he is fit for duty at this time. One would think
that when a department approved doctor states an officer is dealing with too much stress,
that same department would, at the bare minimum, attempt to investigate the extent of the
stress. Instead the department has decided to proceed with its original intent in bringing
the false criminal allegation, and is attempting to begin termination proceedings against
my client.

As stated before my client is suffering from Post Traumatic Stress Disorder which
is the direct result of his being accused of stealing a garden hose which was found within
the department prior to the criminal investigation being commenced, and being forced to
stand trial for a crime he did not commit. For the better part of two years he was forced
to live with uncertainty about his future and then when the matter was finally concluded,
Police Commissioner Amico said in open session that my client was a “thief”. The
department created a hostile work environment and when the matter finally came to a
close the highest governing body within the department decided to weigh in with an
opinion that only worsened the situation. Rather than just letting the situation end
Commissioner Amico felt the need to yell at a taxpaying citizen and then have him
removed from a public meeting because he had the audacity to ask the board a simple
question, and then he referred to my client as a “thief”. My client did not create this
situation, the Ansonia Police Department did and they are still refusing to accept any
responsibility and are refusing to take even one measure to attempt to rectify it.

As to your trying to pull the proverbial “fast” one by scheduling a hearing with
less than one week’s notice, I am not going to stand for that. The hearing can either be
rescheduled with sufficient time to prepare or this action will become just another means
for my client to recover upon the commencement of a civil lawsuit. This complete
disregard of my client’s right to have sufficient notice of a hearing will simply become
the basis for yet another violation of my client’s rights of due process that can be
litigated. I request this hearing be postponed one month for purposes of preparing to
prevent evidence and to obtain the transcripts of the testimony of Chief Hale, and others,
given in the criminal proceeding so it may be used at this hearing. I will also make
additional copies so any interested taxpayers may read it.
 This matter can be dealt with amicably through the proper channels, or it can
become another situation where the taxpayers’ money is spent unnecessarily.

In addition, to save everyone some time and effort I suggest you contact Chief
Kevin Hale who, as of late, he has been the sole voice of reason on the part of the City of
Ansonia, so he can tell you that he long ago authorized my client to hold a job in addition
to his police duties. This issue was addressed in the internal affairs investigation
conducted by the Connecticut State Police in which all charges levied against my client
were unsubstantiated. I fail to see how you can justify the expense to the taxpayer of
investigating an issue in search of an answer that you have had since February of this
year.
Finally, considering my client has a pending CHRO complaint which complains
of the actions of both Robert Goldsen and Nicholas Amico, and my client will be
commencing a civil action against both individuals as well as the city in the coming
months, it is only appropriate, and I specifically request they both recuse themselves from
anything having do to with this matter. One aspect of this claim is Commissioner Amico
referring to my client as a “thief” and then trying to prevent the recording of this incident
from being disseminated to the public. If anyone has trouble recalling this incident I have
a copy of the tape in my possession and will be happy to share it. Again, if these
individuals refrain from recusing themselves any claim for wrongful termination becomes
stronger so proceed as you wish.

Very Truly Yours,

Rob Serafinowicz, Esquire