STATE OF CONNECTICUT

COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES

AFFIDAVIT OF ILLEGAL DISCRIMINATORY PRACTICE

[RETALIATION COMPLAINT]

1. My name is Kelly Baerga, and I reside in the State of Connecticut. As a member of

the Public Safety community, and because of the sexual nature of charges that I am
bringing relative to the violation of my civil rights, I am exercising my right to keep
my home address confidential and off of any records that the public has access
to.

2. I am filing this retaliation complaint subsequent to CHRO Case No. 1910336; EEOC
No. 16A-2019-00650.

3. The respondent is the City of Hartford and the Hartford Police Department, located
at 550 Main Street, Hartford, CT 06103 and 253 High Street in Hartford, CT.

4. The Respondent employs more than 15 persons.

5. In or around March 10, 2019, Mayor Luke Bronin called my personal cell phone from
his personal cell phone and left me a message asking me to contact him or meet with
him in person. The Mayor is the same person who was named in my original CHRO
Affidavit of Illegal Discriminatory Practice dated February 14, 2019 (CHRO 1910336
EEOC No. 16A-2019-00650). I believe this contact by the Mayor, to be pure
retaliation, and an attempt to disregard the seriousness of this complaint, and to
sweep my complaint under the rug.

6. This telephone call from Mayor Luke Bronin, has left me shaken, sickened and
extremely intimidated. I have been unable to return to work because I have been
unable to sleep, crying uncontrollably and deeply depressed. I have lost so much
weight that some of my friends do not recognize me when they see me in the street.
This call from the Mayor of the City, after waiting more than nine months to have my
case resolved, has caused me deep distress and irreparable harm.

7. Because of direct contact from the Mayor of the City, a person that I felt strongly
enough about, to name in my February 14, 2019 CHRO complaint (CHRO No.
1910336), I must now relive the humiliating sexual harassment that I have faced to
date, and I now must schedule appointments with a specialist to address the trauma
that I have been faced with relative to the manner in which my case has been handled
by the City of Hartford and the Hartford Police Department.

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8. Under our current health coverage through the City of Hartford, I now have a high
deductible health plan, and I am not in a position to afford the high deductibles that
come with the medical attention and psychological treatment that I must now obtain
so that I am able to return to work and some form of normalcy.

9. I therefore charge, the City of Hartford and the Hartford Police Department (HPD) with
retaliation against me for engaging in protected activity (the filing of a civil rights sexual
harassment case based on my race, Latino, my gender, female, and my sexual
orientation.)

10. I also charge the Mayor of the City of Hartford, Luke Bronin, with engaging in direct
retaliation against me and attempting to intimidate me by contacting me on my
personal cell phone from his personal cell phone, and leaving me a lengthy voice mail,
asking me to meet with him personally. I have no idea where or how he obtained my
personal cell phone number.

11. Because of this retaliatory and highly intimidating and improper contact on March 10,
2019 by the Mayor of the City, I also charge the City of Hartford and the HPD with
failure to implement or enforce federal, state and local anti-discrimination laws, policies
and practices within the Hartford Police Department in general, and the City of Hartford
in particular.

12. I further ask that the Mayor cease and desist any future attempts to contact me for any
reason. It is within his purview and his responsibility, to order the problems within the
HPD to be corrected through his Chief of Police and his administrative staff. He does
not need to talk to me to resolve every one of the problems facing this department. He
simply needs to order that it be done, and provide the resources necessary, to protect
the women, Blacks and Latinos serve within this department. The Mayor does not
have to talk to me to get this done.

13. The Mayor does not need to talk to me to order the Chief of Police to comply with the
Consent Decree, and Public Act 15-4. He simply needs to order that the HPD comply
with state and federal law. Any attempt to contact me directly lets me know that he is
not attempting to resolve the issues identified within the HPD, but simply to attempt to
coerce me to withdraw my complaint. That is retaliation and intimidation.

14. I have private counsel, and the Mayor is free to talk directly to my attorney.

15. I would like to reiterate a quote from the underlying CHRO complaint in this
matter (CHRO No. 1910336).

“The City of Hartford and the HPD's inaction and failure to protect me from an
armed individual who has a history of purchasing at least one unlicensed

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 assault weapon, has caused physical health issues, including depression,
weight loss, anxiety, hopelessness, sleeplessness and constant and continued
fear of retaliation, as well as fear for my personal safety, and that of my family
members and close friends.

I am under the doctor’s care for multiple conditions related to the failure of the
City of Hartford and the HPD, to protect me from a sexual harasser who
continues to harass me. The City of Hartford and the HPD have spared no
additional resources to deter this kind of behavior in a known sexual harasser.
There has been no disciplinary action taken against this individual, no staff
training on how not to discriminate against protected classes, and no attempt
to comply with federal, state or local civil rights laws and a court ordered
consent decree that would serve to address the issues of disparity based on
race and gender in the HPD.

There is a pattern and practice of employment discrimination against women,

Blacks and Latinos in the HPD, and there is no plan in place to rectify any of
these zero-tolerance violations that have continuously taken place against me
for more than nine months with no resolution in sight. This failure to address
these claims of sexual harassment, has resulted in an ongoing and severely
hostile work environment in a department where the sexual harasser is armed,
angry, and has engaged in threatening behavior against me.

The administration's calloused disregard for issues related to gender, race, and
sexual orientation has created extreme isolation for me, and subjected me to
segregation in the workplace, stereotyping, and public humiliation at the hands
of sworn police personnel.”

These issues need to be addressed IMMEDIATELY, and none of them have been
addressed to date. Now, I am being further intimidated and humiliated with
inappropriate contact from the Mayor of the City of Hartford, in retaliation for my
filing a civil rights complaint, and still, NO PLAN HAS BEEN PRESENTED TO
CORRECT THE BLATANT DISREGARD FOR THE SEXIST, CULTURAL ISSUES
WITHIN THE HARTFORD POLICE DEPARTMENT, and the danger that women,
Latinos and Blacks in the department are facing.

I am now seeking relief through the State of Connecticut Human Rights and Opportunities
(CHRO) in the matters outlined in my retaliation complaint cited above, and I am asking
that CHRO secure for me, protection of my civil and human rights under federal, state
and local civil rights laws, by retaining this complaint for full investigation.

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 OATH OF AFFIRMATION

KELLY BAERGA, affirms, that she is the Complainant herein; that she has

read the foregoing complaint and knows the content thereof; that the same

is true of her own knowledge, except as to the matters herein stated on

information and belief and that as to these matters, she believes the same

to be true.

Dated at Hartford, Connecticut this _____ day of March 2019.

__________________________
Kelly Baerga-Complainant

Subscribed and sworn to before me on this ______ day of March 2019.

________________________________________
Notary Public/Commissioner of the Superior Court

My Commission Expires_____________________