LEGAL DOCUMENTS

COMMONWEATH OF MASSACHUSETTS

1. The PLAINTIFF, Yvonne George, is an individual who resides in the Town of Quincy, Norfolk County, Commonwealth of Massachusetts.
2. The PLAINTIFF, Beverly Plante, in an individual who resides in the Town of Tiverton, State of Rhode Island. Plaintiff, Beverly Plante, is also known as Sister Michaelinda Plante, R.S.M., Sisters of Mercy.
3. At all times relevant, the Plaintiff, Beverly Plante, was employed by the Diocese of Fall River as the Assistant Superintendent of Elementary Schools.
4. The DEFENDANT, The Samaritans of Fall River-New Bedford, Inc. (hereinafter "Samaritans"), is an organization incorporated under the laws of the Commonwealth of Massachusetts with a principal place of business at 386 Stanley Street, Fall River, Bristol County, Commonwealth of Massachusetts.
5. The DEFENDANT, Michael D. Moran, is an individual who resides at [home address on file], Fall River, Bristol County, Commonwealth of Massachusetts.
6. The DEFENDANT, Peter L. Paull, Jr., is an individual who resides at [home address on file], Duxbury, Plymouth County, Commonwealth of Massachusetts.
7. The DEFENDANT, Ellie Leite, is an individual who resides at [home address on file], Swansea, Bristol County, Commonwealth of Massachusetts.
8. At all times relevant, the Defendant, Michael D. Moran, was President of, as well as a member of the Board of Directors for, the Defendant, the Samaritans.
9. At all times relevant, the Defendants, Peter L. Paull, Jr. and Ellie Leite, and each of them, were/are members of the Board of Directors for the Defendant, Samaritans.
10. At all times relevant, the Defendants, Michael D. Moran, Peter L. Paull, Jr., and Ellie Leite, and each of them, acted as agents for the Defendant, Samaritans, and acted within the scope of their authority as members of the Samaritan Board of Directors and/or officers of the Samaritans.
11. At all times relevant, the Defendants, Peter L. Paull and Ellie Leite, and each of them, acted pursuant to instructions given by the Defendant, Michael D. Moran, in his capacity as President of the Samaritans.
    
    
    FACTS
    
    
12. The Plaintiff, Yvonne George, on or about May, 1993, became involved in a "Praise Campaign" to praise and honor the Defendant, Samaritans.
13. Said Praise Campaign produced letters and plaques praising the work of the Defendant, Samaritans, from various political, religious and community leaders.
14. From the receipt of said letters and plaques up to the present, the Defendants, and each of them, made statements to third persons, with full knowledge that such statements were false, that the Plaintiff, Yvonne George, was involved in criminal activity arising from said Praise Campaign. Said third persons include, but are not limited to, Susan Lyman, Edward J. Florino and David Andrews.
15. (number skipped by clerk)
16. Said statements included, but were not limited to, stating that the Plaintiff, Yvonne George, was engaged in "mail fraud" and other forms of "fraud", "dishonest activities" and "criminal activities".
17. On or about June, 1993, the Defendant, Peter L. Paull Jr., at the residence of David Andrews in Pembroke, Massachusetts, stated to Mr. Andrews that the plaintiff, Yvonne George, had "published false articles in the newspaper" and was involved in "criminal activities".
18. On or about July, 1993, the Defendant, Michael D. Moran, during a telephone conversation with Edward J. Florino, Director of Veterans Services, stated that those involved in the above-referred to "Praise Campaign" were committing mail fraud. Defendant, Moran, by implication, during the same telephone conversation, stated that the Plaintiff, Yvonne George, was committing mail fraud.
19. On or about June 15, 1994, at a meeting held in New Bedford, the Defendant, Ellie Leite, and various members of the Defendant, Samaritans, in the presence of third parties stated that the Plaintiffs, Yvonne George and Beverly Plante, had committed "mail fraud" and that they were involved in "criminal activities" and associating with "criminal elements". Said statements were made with the intent to maliciously injure the Plaintiffs' reputations.
20. On or about July 19, 1994, the named Defendants, and each of them, in the presence of Bishop Sean P. O'Malley, O.F.M. CAP, Plaintiff's, Beverly Plante's, superior, made statements about the Plaintiff, Beverly Plante, with the intent to maliciously injure her reputation. Said statements included allegations that the Plaintiff, Beverly Plante, was "associating with criminal elements", that she had "committed mail fraud" and that she was involved in "criminal activities".
21. On or about August 15, 1994, the Plaintiff, Beverly Plante, attended a meeting with Father Richard Beaulieu and Sister Rosemary Laliberte, Plaintiff's, Beverly Plante's, superiors, and various members of the Defendant, Samaritans, including Defendant, Ellie Leite. During said meeting, Defendant Leite and other members of the Defendant, Samaritans, stated that the Plaintiff, Beverly Plante, was "involved in criminal activities", had "committed mail fraud" and was "associating with criminal elements".
22. Due to the false accusations made by the Defendants, and each of them, the Plaintiff, Beverly Plante, was terminated from her employment as the Assistant Superintendent of Elementary Schools for the Diocese of Fall River.
23. Said statements made by the Defendants, and each of them, were made with the intent to maliciously injure the Plaintiff's reputations.
24. The Defendants, and each of them, made the above oral statements with the intent to inflict emotional distress on the Plaintiffs, Yvonne George and Beverly Plante.
25. The Defendants, and each of them, acted in a manner to intentionally and maliciously harass and ridicule the Plaintiffs, Yvonne George and Beverly Plante.
    
    

    COUNT I

    YVONNE GEORGE and BEVERLY PLANTE, VS. ELLIE LEITE, Individually and as a MEMBER OF THE BOARD OF DIRECTORS FOR THE SAMARITANS

    DEFAMATION

    
    
26. The Plaintiffs repeat and reassert the allegations contained in paragraphs one through 25, inclusive, as if set forth in full.
27. Since May, 1993, the Defendant, Ellie Leite has repeatedly made defamatory statements pertaining to the Plaintiffs to third parties within the Samaritans' organization as well as to those associated with the Samaritans.
28. The Defendant, Ellie Leite, has waged and is waging a campaign to harass the Plaintiffs and discredit them by defaming their character in an intentionally malicious manner.
29. The Defendant's, Ellie Leite's outrageous actions have caused the Plaintiffs to suffer, and to continue to suffer, severe emotional distress.
    
    WHEREFORE, the Plaintiffs, YVONNE GEORGE and BEVERLY PLANTE, demand that judgment enter against the defendant ELLIE LEITE for compensatory and punitive damages in an amount to be determined by the court plus interest and costs.
    
    

    COUNT II

    YVONNE GEORGE and BEVERLY PLANTE, VS. MICHAEL D. MORAN, Individually, And as a MEMBER OF THE BOARD OF DIRECTORS FOR THE SAMARITANS

    DEFAMATION

    
    
30. The Plaintiffs repeat and reassert the allegations contained in paragraphs one through 29, inclusive, as if set forth in full.
31. At all times relevant, the Defendant, Michael D. Moran, in his capacity as President of the Samaritans and as a member of the Samaritans' Board of Directors, instructed the other members of the Board, including the Defendants, Ellie Leite and Peter L. Paull, Jr., to harass, ridicule and defame the Plaintiffs, Yvonne George and Beverly Plante.
32. At all times relevant, the Defendant, Michael D. Moran, acted in a malicious and outrageous manner with the intent to inflict financial, physical and emotional harm on the Plaintiffs, Yvonne George and Beverly Plante.
33. The Defendant's, Michael D. Moran's, outrageous actions have caused the Plaintiffs to suffer, and to continue to suffer, severe emotional distress.
    
    WHEREFORE, the Plaintiffs, YVONNE GEORGE and BEVERLY PLANTE, demand that judgment enter against the defendant MICHAEL D. MORAN for compensatory and punitive damages in an amount to be determined by the court plus interest and costs.
    
    

    COUNT III

    YVONNE GEORGE and BEVERLY PLANTE, VS. PETER L. PAULL, JR., Individually, And as a MEMBER OF THE BOARD OF DIRECTORS FOR THE SAMARITANS

    DEFAMATION

    
    
34. The Plaintiffs repeat and reassert the allegations contained in paragraphs one through 33, inclusive, as if set forth in full.
35. The Defendant, Peter L. Paull, Jr., has conspired with the Defendants, Michael D. Moran and Ellie Leite, to wage a campaign to harass the Plaintiffs, Yvonne George and Beverly Plante, and discredit them by defaming their character in an intentionally malicious manner.
36. The Defendant's, Peter L. Paull, Jr.'s, outrageous actions have caused the Plaintiffs, Yvonne George and Beverly Plante, to suffer severe emotional distress.
    
    WHEREFORE, the Plaintiffs, YVONNE GEORGE and BEVERLY PLANTE, demand that judgment enter against the defendant PETER L. PAULL, JR. for compensatory and punitive damages in an amount to be determined by the court plus interest and costs.
    
    

    COUNT IV

    YVONNE GEORGE and BEVERLY PLANTE, VS. THE SAMARITANS OF FALL RIVER- NEW BEDFORD, INC.

    DEFAMATION

    
    
37. The Plaintiffs repeat and reassert the allegations contained in paragraphs one through 36, inclusive, as if set forth in full.
38. At all times relevant, the Defendants, Michael D. Moran, Peter L. Paull, Jr., and Ellie Leite, and each of them, acted as agents for the Defendant, Samaritans, and acted within the scope of their authority as members of the Samaritan Board of Directors and/or officers of the Samaritans.
39. At all times relevant, the Defendant, Samaritans, acted in a malicious and outrageous manner with the intent to inflict financial, physical and emotional harm on the Plaintiffs, Yvonne George and Beverly Plante.
40. The Defendant's, Samaritan's, outrageous actions have caused the Plaintiffs, Yvonne George and Beverly Plante, to suffer, and to continue to suffer, severe emotional distress.
    
    WHEREFORE, the Plaintiffs, YVONNE GEORGE and BEVERLY PLANTE, demand that judgment enter against the defendant SAMARITANS for compensatory and punitive damages in an amount to be determined by the court plus interest and costs.

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