LEGAL DOCUMENTS

1. The plaintiff, Beverly Plante, is an individual who resides in the town of Tiverton, Rhode Island. The plaintiff is also known as Sister Michaelinda Plante, R.S.M., Sisters of Mercy.
2. At all times relevant to this complaint, the plaintiff was employed by the Diocese of Fall River as Associate Superintendent of Elementary Schools.
3. The defendant, the Roman Catholic Diocese of Fall River, in the person of Bishop Sean O'Malley, has offices located at 410 Highland Street, Fall River, Massachusetts, Bristol County. The defendant, Bishop Sean O'Malley, the supervisor of the Diocese of Fall River, and is corporation sole, has his offices at 47 Underwood Street, Fall River, Bristol County, Massachusetts.
4. The defendant, the Samaritans of Fall River, New Bedford, Inc. (hereinafter cited as the "Samaritans") is an organization incorporated under the laws of the Commonwealth of Massachusetts, with a principal place of business at 386 Stantly Street, Fall River, Bristol County, Massachusetts.
   
   
   FACTS
   
   
5. On July 1, 1985, the plaintiff and Bishop Daniel Cronin, the defendant Bishop O'Malley's predecessor as supervising agent for the Diocese of Fall River, entered into a written employment agreement to employ the plaintiff as the Associate Superintendent of Elementary Schools for the Diocese of Fall River.
6. On or about June 30, 1994, the plaintiff, the defendant Bishop O'Malley and the defendant Roman Catholic Bishop of Fall River entered into their tenth (10th) annual employment contract.
7. On July 1, 1994, the plaintiff began to provide her continuing services to the defendant under the terms of that written agreement, and has ever since been and still is ready and willing to continue with such services.
8. On or about May 1993, Yvonne George and other interested individuals, not including the plaintiff, organized a "praise campaign" in order to honor the Samaritans of Fall River/New Bedford for their work on their suicide telephone hotline. On or about July 4, 1993, Yvonne George approached the plaintiff and asked her to make inquiries to the Samaritans regarding personal checks and money orders which had been sent to the Samaritans through this praise campaign, which had gone uncashed yet unreturned. Ms. George also asked the plaintiff to make one $600.00 donation to the "praise campaign" on behalf of the anonymous donor. The plaintiff complied with this very limited request and also made the check inquiries of the Samaritans, which ultimately consisted of five (5) letters.
9. On August 12, 1994, the plaintiff was told by her immediate supervisor, Father Richard Beaulieu, to meet him and the plaintiff's superior, Sister Rosemary Laliberte, on the following Monday, August 15, 1994, in his office.
10. On August 15, 1994, without prior reason or knowledge, the plaintiff was told by Father Beaulieu in the presence of Sister Rosemary Laliberte, that she was to go on involuntary leave of absence for "stress and tiredness." The plaintiff was further instructed by Sister Rosemary Laliberte and Father Beaulieu to obtain a psychological evaluation from Dr. Maureen Malin on August 19, 1994 and to also obtain a complete physical because the defendant Bishop O'Malley had been threatened with a lawsuit by the defendant Samaritans, at least in part due to the actions of the plaintiff.
11. During the above meeting, the plaintiff was complimented for her work as Associate Superintendent, but was told by her superiors Sister Laliberte and Father Beaulieu that the forced leave of absence was a direct result of statements made to the defendant Bishop O'Malley by representatives of the defendant Samaritans.
12. On August 19, 1994, the plaintiff did in fact attend counseling with Dr. Malin and the report of said counselor indicated no clinical criteria for depressive illness or any thought disorder based upon any functional or organic causes. The complete physical evaluation of the plaintiff further indicated no medical abnormalities.
13. The plaintiff, based upon information and belief, as well as upon the fear that she was to be permanently terminated by the defendant Bishop O'Malley and as a direct result of the fear, intimidation and coercive actions of her immediate supervisor Father Beaulieu which included, but was not limited to, reading the plaintiff's mail, listening to and recording the plaintiff's personal phone calls, locking the plaintiff out of her office, and refusing the plaintiff access to her personnel file, was forced to resign in an attempt to salvage her professional reputation.
    
    
    COUNT I
    (Wrongful Termination)
    
    
14. The plaintiff repeats and re-alleges the allegations of paragraphs 1-13 herein.
15. The discharge of the plaintiff from her employment with the Diocese of Fall River was wrongful, in bad faith and in violation of her employment contract.
16. As a direct result of the plaintiff's wrongful termination, she has suffered damages, including but not limited to her loss of salary under the terms of her contract, her loss of residence, her loss of professional reputation and her subsequent inability to seek further employment.
    WHEREFORE, the plaintiff demands:
17. Judgment against the defendant O'Malley and the defendant Roman Catholic Diocese of Fall River in the person of Bishop O'Malley jointly and severally for the damages above described, interest and costs.
18. Such other relief as this Court deems proper and just.
    
    
    JURY DEMAND
    
    The plaintiff demands trial jury on all of the above issues.
    
    
    COUNT II
    (Intentional Interference
    With Contractual Relations)
    
    
19. The plaintiff repeats and re-alleges the allegations of paragraphs 1-16 herein.
20. On September 20, 1993, the defendant Samaritans sent a letter through their board member employee and agent, Attorney Peter Paull, Jr., to the plaintiff's superior, Sister Rosemary Laliberte, which threatened the plaintiff with a restraining order and telephone traps of her incoming calls, as well as alleged that she had committed mail fraud and illegal fund raising.
21. On July 19, 1994, the defendant Samaritans sought and arranged a meeting with defendant Bishop O'Malley and threatened the Diocese with a lawsuit in the plaintiff's alleged activities, which were not true, did not stop.
22. The defendant Samaritans, who despite knowledge of the plaintiff's long employment for Diocese of Fall River, and without lawful justification, interfered in the plaintiff's contractual relationship with the Diocese of Fall River, by engaging in the above improper conduct.
23. As a direct and proximate result of the defendant Samaritans' interference with the plaintiff's employment relationship with the Diocese of Fall River, the plaintiff was forced to resign her position and was terminated from her position as Associate Superintendent on the Elementary Schools of the Diocese of Fall River, thereby suffering loss and damages, including but not limited to her loss of salary, her lost renewal of her contract, her lost professional reputation, her loss of residence, and her subsequent inability to seek further employment.
    WHEREFORE, the plaintiff prays and demands:
24. Judgment against the defendant Samaritans for damages above described, including interest and costs.
25. Such other relief this Court deems proper and just.

The plaintiff requests a trial by jury on all the above issues.

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