JEFFERY DIEFFENBACH v. GREENLEAF COMPASSIONATE CARE CENTER, INC.

Case 1:20-cv-00413-MSM-PAS Document 1 Filed 09/16/20 Page 1 of 23 PageID #: 1
UNITED STATES DISTRICT COURT FOR

THE DISTRICT OF RHODE ISLAND
JEFFERY DIEFFENBACH,
Plaintiff CA No: 1:20-cv-00413
v. PLAINTIFF DEMANDS A TRIAL BY JURY
GREENLEAF COMPASSIONATE
CARE CENTER, INC.,
Defendant
COMPLAINT
This action is commenced by JEFFERY DIEFFENBACH (hereinafter “Plaintiff”)
against GREENLEAF COMPASSIONATE CARE CENTER, INC. (hereinafter “Employer,”
“Greenleaf,” or “Defendant”) to remedy and seek relief for unlawful employment practices
arising under The Age Discrimination in Employment Act of 1967, 29 U.S.C. § 623(a) and §
623(d) (“ADEA”), Title I of the Americans with Disabilities Act 42 U.S.C. §§ 12112, 12203
(“ADA”), Rhode Island Fair Employment Practices Act, , R.I. Gen § 28-5-1 et seq., (“FEPA”),
the Rhode Island Civil Rights Act of 1990, R.I. Gen. Law § 42-112-1 et seq. (hereinafter
“RICRA”), and Rhode Island Whistleblowers’ Protection Act (“WPA”), R.I. Gen. Law § 28-50-
1, et seq.
PARTIES
1. Plaintiff Jeffery Dieffenbach presently resides in the City of Newport, County of Newport,
within the State of Rhode Island and formerly worked for Defendant for nearly six (6) years.
2. Defendant Greenleaf Compassionate Care Center, Inc. is a domestic non-profit corporation and
licensed and regulated medical marijuana dispensary doing business in the State of Rhode
Island in the Town of Portsmouth, County of Newport, within the State of Rhode Island.
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JURISDICTION AND VENUE
3. This Court has jurisdiction to hear the Complaint pursuant to 28 U.S.C. § 1331.
4. This Court has supplemental jurisdiction over Plaintiff’s state law claims pursuant to 28 U.S.C.
§ 1367. Plaintiff’s state claims are so related to Plaintiff’s federal claims that they form part of
the same case or controversy. Consideration of judicial economy, fairness, and convenience
warrants this Court’s exercise of supplemental jurisdiction over Plaintiff’s state law claims.
5. Venue of this action lies pursuant to 28 U.S.C. § 1391(b) because Defendant conducts business
in, the alleged unlawful practices occurred in, and the records relevant to the alleged unlawful
practices are maintained in Defendant’s place of business within the state of Rhode Island and
the judicial district of this Court.
ADMINISTRATIVE PROCEDURES
6. Charges of Discrimination were timely filed by Plaintiff with the Rhode Island Commission of
Human Rights (RICHR) on or about February 24, 2020 and the charges were co-filed with the
Equal Employment Opportunity Commission (EEOC).
7. On or about July 30, 2020, the RICHR issued a Notice of Right to Sue (RICHR NO. 20 EPD
159-04/31) and subsequently the EEOC (EEOC NO.16J-2020-00105) issued the same enabling
a private civil action to be filed.
8. This Complaint was timely filed after issuance of the Notice of the Right to Sue.
FACTUAL ALLEGATIONS
9. Plaintiff is a 71-year old male who is a licensed, non-practicing (Connecticut) attorney and
inactive CPA accountant with a long and impressive job history.
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10. At the time Plaintiff was unlawfully terminated from Greenleaf on January 13, 2020, his job
was Director of Finance and General Counsel for Greenleaf, a title bestowed upon him by
Greenleaf and its majority owner Dr. Seth Bock in or about March of 2018.
11. However, Plaintiff worked for Greenleaf for nearly six (6) years in total.
12. By way of background, in or about March of 2014, Plaintiff was hired part-time as an
Independent Contractor for Defendant, a medical marijuana licensed dispensary in Portsmouth,
RI, to do bookkeeping, QuickBooks maintenance, bank reconciliations, tax planning, budgeting,
cash flow analysis, and eventually compliance and payroll.
13. At first Plaintiff was paid $30.00 per hour for 10 hours a week but his role grew extensively
over his six-year-tenure due to his superb performance and Greenleaf’s growth; by October
2018 Plaintiff was being paid $90,000.00 per year as the Director of Finance and General
Counsel.
14. Dr. Seth H. Bock (hereinafter “Dr. Bock”), an acupuncturist, is the majority owner of Greenleaf
while Richard Radebach (“Mr. Radebach”) is the other owner; upon information and belief,
their ownership interests are 55% and 45% respectively.
15. Greenleaf is a non-profit corporation and thus subject to the RI Non-Profit Corporation Act,
RIGL 7-6-1 et seq.
16. At all times relevant, Plaintiff’s job performance met or exceeded Defendant’s reasonable
expectation.
17. As a person trained in law and accounting, at all times relevant, Plaintiff was sensitive to his
and all of leadership’s fiduciary duty to the entity of Greenleaf.
18. Starting in mid-2017, Plaintiff learned information about minority owner Mr. Radebach’s
operation of other businesses that Plaintiff believed conflicted with his fiduciary duty to
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Greenleaf; Plaintiff also learned information about Greenleaf’s external accountant and tax
advisor, Marc A. Cohen (hereinafter “Mr. Cohen”) of Cohen & Associates, LLC, and his
involvement in, or financial ties to, the other businesses associated with Mr. Radebach.
19. For example, Plaintiff learned that Mr. Radebach had an employment duty to not compete with
Greenleaf but that he devoted much of his time to an unrelated healthcare company, The
Wellness Company, in Providence, RI, and was also developing a competing marijuana
dispensary, Alternative Compassion Services, Inc. in Bridgewater, MA.
20. Plaintiff had learned, around that same time, about Mr. Cohen’s suspected involvement in these
businesses including his financial involvement.
21. Plaintiff also learned that Mr. Radebach’s son was working for Greenleaf only to gain skills to
leave and run his father’s competing dispensary, Alternative Compassion Services, Inc.
22. Plaintiff began to share these concerns about potential self-dealing, conflict of interest, and
breach of fiduciary duty by Mr. Radebach with majority owner Dr. Bock in or about mid-2017.
23. For example, in July of 2017, in response to a pointed question by Dr. Bock about the
distinction between Plaintiff’s and Mr. Radebach’s job as the Chief Financial Officer, Plaintiff
first shared concerns about Mr. Radebach and that in Plaintiff’s personal opinion, he could be in
breach of his fiduciary duties to Greenleaf by self-dealing, having conflicts of interest, and be in
breach of his employment agreement because of running a competing business.
24. Armed with the information from Plaintiff, on or about September 19, 2017, Dr. Bock wrote an
email to Mr. Radebach where he raised the concerns Plaintiff outlined about Mr. Radebach’s
conflicts and requested that Mr. Radebach revise his employment agreement at a reduced salary
due to the time spent in his other businesses.
25. Mr. Radebach refused and Dr. Bock did not press the issue.
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26. However, it was at this point, in late 2017, that Mr. Radebach first learned that Plaintiff was
reporting perceived violations of law to the President/CEO and majority owner of Greenleaf,
Dr. Bock.
27. After Mr. Radebach became aware of Plaintiff’s reports, he began retaliating against Plaintiff in
an increasing fashion; the more Plaintiff reported or probed over the years, the more Mr.
Radebach retaliated.
28. About a month later, in October 21, 2017, Plaintiff wrote a confidential memo to Dr. Bock
expressing concerns that the Greenleaf Board be restructured to include an independent CPA or
attorney and that a Compensation Committee be established.
29. Then at the end of 2017, Mr. Radebach’s son left his job as Greenleaf’s Operating Manager to
work at his father’s competing dispensary as COO and, upon information and belief, took
valuable contact lists, accounting data, and other trade secrets to the competing business and
tried to recruit Greenleaf staff to work there, all with Mr. Radebach’s approval; Plaintiff
expressed concerns about these events to Dr. Bock.
30. Upon information and belief, Mr. Radebach learned of these communications as well.
31. In or about January of 2018, Plaintiff introduced Dr. Bock to a potential buyer for Greenleaf;
Dr. Bock put Plaintiff in charge of all due diligence inquiries by the acquiring company.
32. As part of his duties related to due diligence, in or about March of 2018, Dr. Bock asked
Plaintiff to review the financials of Greenleaf Compassion Ventures, LLC, (hereinafter “GCV”),
the real estate holding company owned by both Dr. Bock and Mr. Radebach, with ownership
percentages upon information and belief, of 50% and 50% respectively.
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33. Upon initial review, it became apparent to Plaintiff that Mr. Radebach solely managed GCV and
upon information and belief, had neither given Dr. Bock financial statements nor access to the
Credit Union bank account.
34. Soon after that, on or about April 11, 2018, during a routine budget review, and with the
authority of Dr. Bock, Plaintiff asked Mr. Radebach for the Credit Union password.
35. In response, Mr. Radebach got irate and yelled at Plaintiff, “[t]his is not for you to review, we’ll
get a separate bookkeeper for GCV. It’s a sperate company and none of [Plaintiff’s] business.”
36. Later that morning, at 10:30 am in the Portsmouth RI parking lot, while Plaintiff was getting
into his car, Mr. Radebach threatened him, stating, “I mean it, do not get involved with GCV or
else.”
37. Plaintiff immediately reported Mr. Radebach’s threat to Dr. Bock and Russell Carlone
(hereinafter “Mr. Carlone”), Director of Compliance and former Newport Police Captain.
38. Plaintiff asked Mr. Carlone to print out a copy of the video from the internal surveillance
camera as proof of Mr. Radebach’s confrontation in the parking lot.
39. Mr. Carlone declined to do so, saying he would give Plaintiff verbal support, if needed.
40. However, soon after, Dr. Bock asked Plaintiff to not report the event outside of the company as
he had intended, for fear of the impact on the pending potential sale.
41. From that day forward, Plaintiff worked in fear of Mr. Radebach; this created an ongoing
hostile work environment where Plaintiff feared Mr. Radebach and had to avoid one-on-one
meetings with him, which made it extremely uncomfortable to perform his duties.
42. Mr. Radebach’s threat and his ongoing hostility towards Plaintiff was in direct retaliation for
Plaintiff’s ongoing reports of Mr. Radebach’s perceived violations of law to Dr. Bock.
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43. Notably, in 40 years of business, accounting, and legal work, Plaintiff had never been
threatened or harassed, so it was an extremely uncomfortable situation at work for Plaintiff.
44. Nonetheless, out of duty to Greenleaf and Dr. Bock, Plaintiff continued his review of GCV
finances, despite Mr. Radebach’s threats, at the behest of Dr. Bock.
45. Based on the extensive excel spreadsheets for the years of 2015-2017, Plaintiff discovered that
Mr. Radebach had used GCV money to pay for his own personal life insurance, to provide
distributions that Plaintiff did not believe were authorized, and to pay personal expenses;
Plaintiff estimated the total amount of money he believed was misappropriated from GCV for
Mr. Radebach’s personal use (at that time) was approximately $30,326.00.
46. Plaintiff also later discovered that from 2016 through 2019, Mr. Radebach took money from
Greenleaf to pay GCV’s bills when the money was short, such as paying outdoor paving,
HVAC repairs, even GCV’s mortgage pay off, all totaling approximately $69,369.00.
47. Plaintiff shared what he had found with Dr. Bock who asked him for a name of an accountant
who could perform a forensic audit of GVC.
48. In or about May of 2018, Plaintiff began discussions with an independent accounting firm at the
request of Dr. Bock, however, prior to the engagement, Dr. Bock asked him to drop the matter.
49. In June of 2018, the potential buyer signed a letter of intent with Greenleaf.
50. Around this time in 2018, Mr. Radebach hired, Channa Lincoln (hereinafter “Ms. Lincoln”),
one of the partners of Greenleaf’s payroll providing company, Balanced Books, Inc., causing
her to leave the service of Greenleaf, and he gave her a job at his other company, The Wellness
Company, running payroll and accounting.
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51. Ms. Lincoln, who was substantially younger than Plaintiff and without perceived disabilities,
was eventually re-hired by Greenleaf to take over some of Plaintiff’s duties, while still
employed, and to replace him, after termination.
52. In or about June of 2018, Greenleaf received notice of an IRS Audit for the 2016 taxable year.
53. In or about August of 2018, as part of the due diligence process by the prospective acquiring
company, an outside accounting firm produced a report indicating potential tax adjustments for
2015-2016 due to Mr. Cohen and Mr. Radebach’s incorrectly reported income tax deductions.
54. Separately, one of the findings by that accounting firm was that despite pay of $260,000
annually, “Mr. Radebach does not perform any meaningful function in finance or
accounting…we recommend that you review all key management positions and compensation
arrangements”.
55. During the IRS audit process, from about November of 2018 through the summer of 2019, Mr.
Cohen and Mr. Radebach asked Plaintiff to provide information to the IRS, about the business,
that Plaintiff did not believe was correct.
56. Plaintiff refused to comply with these requests.
57. Resisting and refusing to do what Plaintiff believed to be a violation of law is a protected act, as
is reporting perceived violations of law, under the Rhode Island Whistleblower Protection Act.
58. Then, on or around December 24, 2018, Mr. Radebach instructed the company’s payroll service
provider Ms. Lincoln to cause a “bonus” in the amount of $13,040.29 net of withholding to be
paid to or on behalf of Mr. Radebach; the payment was, upon information and belief, not for
services rendered but was to pay personal expenses on Mr. Radebach’s personal Visa Card.
59. Plaintiff reported these concerns to Dr. Bock.
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60. Then, in April of 2019, Mr. Radebach caused $200,000 to be distributed to himself and another
$200,000 to be distributed to Dr. Bock from Greenleaf’s bank account, on top of their salary;
soon thereafter Mr. Radebach distributed another $44,000.00 to Dr. Bock to match his
ownership interest.
61. The RI Nonprofit Corporation Act, RIGL 7-6-31 through 7-6-32 prohibit loans to directors,
distributions to directors or officers, and requires reasonable compensation for services
rendered.
62. Plaintiff reported his concerns regarding Mr. Radebach’s distributions of $200,000.00 to
himself, and two distributions equaling $244,000.00 to Dr. Bock, to several people including
Dr. Bock, Attorneys at Adler, Pollack, and Sheehan, and even Mr. Radebach,
63. Because of similar concerns, Greenleaf’s attorneys at Adler, Pollack, and Sheehan later
instructed Mr. Radebach and Mr. Bock to execute Promissory Notes with stated interest to
comply with the filing requirements of Form 2 of the RI Department of Business Regulations.
64. Then in June of 2019, Mr. Cohen and Mr. Radebach put Plaintiff in an extremely uncomfortable
situation due to pressure to mislead the IRS regarding the audit.
65. Specifically, Mr. Cohen had compiled certain requested information for the IRS and as to the
explanation of the information, he informed Mr. Radebach, Mr. Bock, and Plaintiff, in email,
that he was intentionally “leaving it unclear and allowing her to interpolate for now” which
Plaintiff perceived as misleading the IRS agent.
66. Plaintiff raised his concerns about misleading the IRS due to his perception it would violate law.
67. At this same time in the summer of 2019, Plaintiff also began to re-report, in a stronger manner
and to more of leadership, that Plaintiff believed Mr. Radebach had unlawful self-dealing,
conflicts of interest, fund misappropriation and other violation of fiduciary duties such as
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continuing to work for other entities including a competing entity; Plaintiff reported these
concerns to not just Dr. Bock, but also to Russell Carlone, Director of Compliance and Petra
Napolitano, Chief Operating Officer (hereinafter “Ms. Napolitano”).
68. Upon information and belief, it was at this time in the summer and fall of 2019, that leadership
of Greenleaf decided that Plaintiff was a liability due to his ongoing whistleblowing activities,
as well as due to his advanced age and perceived medical conditions.
69. As such, suddenly Plaintiff’s age and perceived medical conditions became an issue, as if it was
implied he should retire or leave, and as an express excuse to strip Plaintiff’s duties.
70. For example, Ms. Napolitano, started calling Plaintiff the “silver fox,” the IT Manager called
Plaintiff “old fashioned” referring to his physical vendor files; Plaintiff was also harassed about
his antiquated record keeping and manual time keeping procedures.
71. Moreover, Plaintiff’s job began to be stripped systematically and reassigned to younger, non-
disabled or perceived-disabled employees who were also not complaining about violations of
law; the job change Plaintiff experienced over the next few months was striking.
72. Notably, financial reasons cannot form the basis for the reduction of Plaintiff’s job duties or
later termination because, at this same time, upon information and belief, Dr. Bock earned $1
million per year and Mr. Radebach earned $462,000.00 per year from this non-profit.
73. The first job duty taken away in the last few months of Plaintiff’s nearly six (6) years of
employment with Greenleaf was the overseeing of payroll.
74. The excuses at first given by Ms. Napolitano, in conjunction with Mr. Radebach and Dr. Bock,
was to bring in another person to this role because there needed to be a “backup.”
75. When Plaintiff asked why he needed a backup, he was told in case he got “sick.”
76. Younger workers did not have “backups” assigned in case they are sick.
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77. Then, Mr. Radebach directed Ms. Napolitano to take over the company budget from Plaintiff;
Ms. Napolitano confided in Plaintiff that she had no experiencing with forecasting and budgets.
78. Plaintiff had provided budgets each calendar quarter for five years, which was a sizable part of
his job; it was stripped away from him without explanation other than the need for a “backup.”
79. Then on November 19, 2019, Plaintiff had a routine wellness appointment with his doctor to
help prevent recurrence of pneumonia which he had experienced the prior summer.
80. When Plaintiff returned to work on November 20, 2019, Saje Desjarlais (hereinafter “Ms.
Dejarlais”), Director of Data Analytics and Inventory Control, asked him, “[h]ow was the lung
biopsy?”
81. Plaintiff replied “[w]hat? I did not have a lung biopsy, it was a routine check-up.”
82. Plaintiff then asked, “[w]here did you get that information?”
83. Ms. Desjarlais told him the information came from Ms. Gardner, the HR manager; Ms. Gardner
was one of many in Greenleaf leadership who were consistently raising Plaintiff’s age and
health at that time.
84. Plaintiff asked what else Ms. Gardner had said about him with respect to his health or age but
Ms. Desjarlais would not provide any more information.
85. Not long after that, Ms. Gardner started to treat Plaintiff very poorly; she was unjustifiably
argumentative and went out of her way to embarrass Plaintiff in front of other leaders.
86. Plaintiff complained to Dr. Bock about Ms. Gardner’s behavior which Plaintiff felt was
discriminatory based on his age and her perception that he had a medical conditions (disability)
requiring a lung biopsy.
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87. Following Plaintiff’s complaints about harassment by the HR manager, Ms. Gardner, to Dr.
Bock, Ms. Gardner retaliated against Plaintiff by trying to discredit him in front of Dr. Bock and
others including Ms. Napolitano and Mr. Carlone.
88. Then at a managers’ meeting on December 10, 2019, Ms. Gardner again tried to publicly
degrade Plaintiff before other leaders.
89. Plaintiff formally reported Ms. Gardner to Mr. Carlone at that point.
90. Specifically, on or about December 21, 2019, Plaintiff emailed Mr. Carlone to complain about
Ms. Gardner’s inappropriate outbursts of anger and continued retaliation towards him.
91. Plaintiff also reported to Mr. Carlone that, most disturbingly for someone in an HR role, Ms.
Gardner had spread mis-information that Plaintiff had some form of medical condition, or
disability, because he “had a lung biopsy”; this implied that she believed he was both old and
sick, thus incapable of doing his job.
92. Plaintiff was humiliated so much so that Plaintiff felt he had to reassure Mr. Carlone that he was
healthy and could do his hob.
93. Mr. Carlone responded by agreeing with Plaintiff that Ms. Gardner was not qualified for HR;
upon information and belief, her qualifications were in customer service and sales, not HR.
94. However, Mr. Carlone and Greenleaf did nothing with respect to swift remedial measures to
stop the age and perceived disability-based harassment by Mr. Gardner at that time in or about
mid-December of 2019.
95. Then in response to Plaintiff’s formal complaint about discrimination to Mr. Carlone and his
ongoing reports of the perceived violations of law by Mr. Radebach, Mr. Radebach suddenly
directed Greenleaf to re-hire his other company’s payroll and accounting provider, Ms. Lincoln,
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for a position at Greenleaf to take over some of Plaintiff’s duties, even though Plaintiff was still
doing those duties at the time and had no intention to stop doing those duties.
96. Plaintiff complained to Ms. Napolitano that Ms. Lincoln’s involvement in Mr. Radebach’s other
companies made her a poor hiring decision; Mr. Radebach and Ms. Napolitano overruled
Plaintiff.
97. However, instead of being his “backup,” Plaintiff’s payroll work was “completely removed
from [Plaintiff’s] desk” and given to the substantially younger, non-disabled, non-complaining
Ms. Lincoln.
98. Then, on or about January 7, 2020, at another managers’ meeting, Ms. Gardner again tried to
publicly humiliate Plaintiff when he raised that the health insurance manifest was incorrect.
99. On January 8, 2020, Plaintiff met with Mr. Carlone to again formally complain about Ms.
Gardner and this time, also raised his right to protection under the Rhode Island Whistleblower
Protection Act; he also reiterated Ms. Gardner’s harassment about him having a “lung biopsy.”
100. On January 9, 2020, Plaintiff filed a formal internal written complaint against Ms. Gardner
alleging facts to support age and perceived disability discrimination and included a sworn
affidavit.
101. Finally, Mr. Carlone started an investigation, apparently, and interviewed Plaintiff briefly.
102. On Friday, January 10, 2020, Plaintiff further complained to Ms. Napolitano that Ms. Lincoln
was not appropriate for the payroll role at Greenleaf because she “still works for Mr. Radebach
at Wellness” and she had helped take out that “bonus” that was used to pay personal expenses
on Mr. Radebach’s personal Visa Card.
103. Ms. Napolitano responded, “well that’s new information.”
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104. Later that same day on January 10, 2020, Plaintiff’s access to the payroll software, which he
needed to do his remaining work, such as preparing taxes, was blocked.
105. Plaintiff scheduled a meeting with Ms. Napolitano and Mr. Carlone for Monday, January 13,
2020 at 2:30 pm to provide evidence proving that Ms. Lincoln and Mr. Radebach had
conflicts of interest and Mr. Radebach had improperly used Greenleaf funds for personal use.
106. On January 12, 2020, Plaintiff filed a second formal written complaint, this time to Dr. Bock
and Mr. Carlone, (received January 13, 2020) alleging various acts of self-dealing, conflict of
interest, misappropriation of funds, alleged deceit of the IRS and other perceived violations of
law by Mr. Radebach.
107. Early in the morning of January 13, 2020, Dr. Bock suddenly texted Plaintiff saying he
needed to talk to him.
108. Plaintiff entered Greenleaf’s conference room to find Dr. Bock and Mr. Radebach holding his
phone as if he were recording the conversation, and Dr. Bock said “We have to let you go, it’s
unfortunate” and said “I want to give you some information, you are leaving because your
work was unsatisfactory”; Dr. Bock indicated he had some paperwork for Plaintiff.
109. Plaintiff responded by asking him to send that information via an email but felt uncomfortable
that he believed Mr. Radebach was recording him, so he said little else.
110. No explanation was ever provided as to what performance problem was claimed; throughout
his nearly six years at Greenleaf he had received no negative feedback as to his performance;
notably, much later in response to the charges, Greenleaf fabricated reasons including late
work and related criticisms that had never been brought up or documented prior to that time.
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111. Plaintiff was fired before he was able to attend the meeting where he was going to provide
evidence to Ms. Napolitano and Mr. Carlone proving that Ms. Lincoln and Mr. Radebach had
conflicts of interest and Mr. Radebach had improperly used Greenleaf funds for personal use.
112. After Plaintiff was fired, Dr. Bock, Mr. Radebach, and Mr. Carlone failed to continue their
investigation into Plaintiffs allegations of harassment/discrimination and violation of the
protections provided by the Whistleblower Act.
113. Plaintiff was replaced by the hiring of the substantially younger, non-disabled Ms. Lincoln
who took over a large portion of Plaintiff’s job; Plaintiff’s other duties were absorbed by Ms.
Gardner and Ms. Napolitano (both also substantially younger and non-disabled) despite a lack
of qualifications to do so.
114. Upon information and belief, Plaintiff was terminated because of age and perceived health
conditions (i.e. perceived disability).
115. Upon information and belief, Plaintiff was terminated in retaliation for - and extremely
proximate to - making a series formal oral and written complaints about age and perceived
disability harassment and discrimination.
116. Upon information and belief, Plaintiff was also terminated in retaliation for his whistleblowing
about Mr. Radebach and Mr. Cohen’s unlawful activities that Plaintiff believed violated law.
117. In or about April of 2020, following Plaintiff initially filing his claim in the Rhode Island
Commissions for Human Rights, Dr. Bock represented publicly, and under oath, that Plaintiff
unilaterally assigned himself the title of General Counsel without Greenleaf’s authority1 and

1
Which is untrue as demonstrated by nearly 2 years of emails to Dr. Bock with that job title listed under Plaintiff’s
name and demonstrated through an organizational chart, with Plaintiff’s job including “General Counsel,” which Dr.
Bock himself submitted as part of the due diligence package to at least one prospective buyer.
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incorrectly represented that Plaintiff was not qualified as General Counsel because he was not
a Rhode Island licensed attorney2.
118. Such false statements were in retaliation for Plaintiff filing his charges of discrimination
against Greenleaf and such false claims were harmful to Plaintiff’s busines reputation.
119. These retaliatory statements were intended to impugn Plaintiff’s credibility and integrity and
resulted in causing Plaintiff emotional distress, humiliation, and other damages.
120. Of note, in response to Plaintiff learning of these false statements, Plaintiff requested a
retraction from Dr. Bock; Plaintiff even provided evidence showing that the title of General
Counsel was not only authorized by Greenleaf and Dr. Bock, it was used for nearly two years
in emails to Dr. Bock himself and was the authorized job title Dr. Bock used on Greenleaf’s
organizational chart submitted to at least one prospective buyer in due diligence.
121. Defendant and Dr. Bock, to date, have never retracted their untrue statements which has
caused Plaintiff additional and ongoing distress and damages.
122. As a direct and proximate result of Defendant’s and its agent’s acts and omissions, Plaintiff
suffered and continues to suffer loss of income and earning capacity; loss of work-related
benefits, privileges, promotions, and status; experienced humiliation, and loss of standing in the
community; suffered and continue to suffer from extreme emotional distress and mental anguish
resulting in physical injury; and suffered other injuries. All damages continue to date.

2
Plaintiff is licensed in the state of Connecticut and, as inside counsel, he need not be licensed in the state of Rhode
Island. See R.I. R. of Prof. Conduct 5.5 (d) (allows in-house counsel to possess a current license in another state).
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COUNT ONE
AGE DISCRIMINATION – DISCRIMINATORY TERMS AND CONDITIONS
AGE DISCRIMINATION – DISCRIMINATORY TERMINATION
Violation of the Age Discrimination in Employment Act of 1967, 29 U.S.C. § 623(a) and §
623(d) (ADEA), Violation of RI Fair Employment Practices Act, R.I. Gen 1956 § 28-5-1 et seq.
(FEPA), and Rhode Island Civil Rights Act of 1990, R.I. Gen. Law § 42-112-1 et seq. (RICRA)
123. ALL Paragraphs are hereby incorporated by reference in their entirety as if fully stated herein.
124. Plaintiff was protected from age discrimination under the ADEA, 29 U.S.C. § 623(a) (“ADEA”)
and R.I. Gen 1956 § 28-5-1 et seq. (“FEPA”) and R.I. Gen. Law § 42-112-1 et seq. (RICRA).
125. Defendant’s agent subjected Plaintiff to disparate treatment and harassment because of age
which changed the terms and conditions of his employment in the ways stated above.
126. Defendant’s agents knew of the disparate treatment, which was perpetrated by several of
Greenleaf leadership, because of multiple complaints to Dr. Bock and Mr. Carlone.
127. Defendant’s agents, however, failed to take swift, remedial action in violation of, inter alia,
ADEA, FEPA, and RICRA.
128. Defendant’s agents terminated Plaintiff because of his age in violation of, inter alia, ADEA,
FEPA, and RICRA.
129. But for Defendant’s agents’ intentional discrimination, Plaintiff would not have been terminated.
130. Defendant’s agents’ discriminatory conduct, policies, and practices, described above, were
intentionally discriminatory, motivated by animus, impermissible and unlawful considerations
and violate, inter alia, ADEA, FEPA, and RICRA.
131. Plaintiff experienced the damages aforesaid as a proximate result of Defendant’s agents’
intentional conduct.
132. Because Defendant’s conduct was intentional, constitutes gross negligence, recklessness, and
was willful and/or wanton, punitive or exemplary damages are warranted.
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133. Defendant is vicariously responsible for the acts and omissions of its agents under Respondeat
Superior.
134. Plaintiff seeks multiple damages under the ADEA.
COUNT TWO
RETALIATION – RETALIATORY TERMS AND CONDITIONS
RETALIATION – RETALIATORY TERMINATION
Violation of the Age Discrimination in Employment Act of 1967, 29 U.S.C. § 623(d) (ADEA),
Violation of RI Fair Employment Practices Act, R.I. Gen 1956 § 28-5-1 et seq. (FEPA), and
Rhode Island Civil Rights Act of 1990, R.I. Gen. Law § 42-112-1 et seq. (RICRA)
136. Plaintiff was protected from retaliation under the ADEA, 29 U.S.C. § 623(D) (“ADEA”), R.I.
Gen 1956 § 28-5-1 et seq. (“FEPA”), and R.I. Gen. Law § 42-112-1 et seq. (RICRA).
137. Plaintiff engaged in protected conduct, opposed unlawful conduct, and exercised his rights
under the ADEA, FEPA, and RICRA by reporting discriminatory treatment and harassment by
Greenleaf leadership that was because of age to Dr. Bock, Mr. Carlone, and Ms. Napolitano.
138. As a result of Plaintiff’s protected activity, Plaintiff was subjected to disparate treatment and
harassment which changed the terms and conditions of his employment in the above ways.
139. Defendant’s agents knew of the retaliatory conduct because it was reported to Dr. Bock, Mr.
Carlone, and Ms. Napolitano, but failed to take swift, remedial action in violation of, inter alia,
ADEA, FEPA, and RICRA.
140. Defendant’s agents terminated Plaintiff in retaliation for - and extremely proximate to - his
protected activity in violation of, inter alia, ADEA, FEPA, and RICRA.
141. But for Defendant’s agents’ retaliatory conduct, Plaintiff would not have been terminated.
142. Defendant’s agents’ retaliatory conduct, policies, and practices were intentionally retaliatory,
motivated by animus, impermissible and unlawful, thus violating, inter alia, ADEA, FEPA, and
RICRA.
18

143. Plaintiff experienced the damages aforesaid as a direct and proximate result of Defendant’s
agents’ intentional conduct.
145. Defendant is responsible for the acts and omissions of its agents under the theory of Respondeat
Superior.
146. Plaintiff seeks multiple damages under the ADEA.
COUNT THREE
DISABILITY DISCRIMINATION –TERMS AND CONDITIONS
DISABILITY RETALIATION – TERMINATION
Violation of Americans With Disabilities Act 42 U.S.C. § 12112 (ADA), Violation of RI Fair
Employment Practices Act, R.I. Gen 1956 § 28-5-1 et seq. (FEPA), and Rhode Island
Civil Rights Act of 1990, R.I. Gen. Law § 42-112-1 et seq. (RICRA)
148. Plaintiff was protected from discrimination based on actual, perceived, or a record of disability
under the Americans with Disabilities Act § 12112 (“ADA”), R.I. Gen 1956 § 28-5-1 et seq.
(“FEPA”) and R.I. Gen. Law § 42-112-1 et seq. (“RICRA”).
149. Defendant’s agent subjected Plaintiff to disparate treatment and harassment because of
perceived disability related to Plaintiff needing a lung biopsy, which changed the terms and
conditions of his employment in the ways stated above.
150. Defendant’s agents knew of the disparate treatment, which was perpetrated by Greenleaf
leadership, because of multiple complaints to Dr. Bock and Mr. Carlone.
151. Defendant’s agents, however, failed to take swift, remedial action in violation of, inter alia,
ADA, FEPA, and RICRA.
152. Defendant’s agents terminated Plaintiff because of his perceived disability in violation of, inter
alia, ADA, FEPA, and RICRA.
19

153. But for Defendant’s agents’ intentional discrimination, Plaintiff would not have been terminated.
154. Defendant’s agents’ discriminatory conduct, policies, and practices, described above, were
intentionally discriminatory, motivated by animus, impermissible and unlawful considerations
and violate, inter alia, ADA, FEPA, and RICRA.
Superior.
COUNT FOUR
DISABILITY RETALIATION –RETALIATORY TERMS AND CONDITIONS
DISABILITY RETALIATION –RETALIATORY TERMINATION
Violation of Americans With Disabilities Act 42 U.S.C. § 12203 (ADA), Violation of RI Fair
Employment Practices Act, R.I. Gen 1956 § 28-5-1 et seq. (FEPA), and Rhode Island
Civil Rights Act of 1990, R.I. Gen. Law § 42-112-1 et seq. (RICRA)
159. Plaintiff was protected from retaliation for protected conduct such as reporting disability-based
harassment and discrimination, under the Americans with Disabilities Act § 12203 (“ADA”), R.I.
Gen 1956 § 28-5-1 et seq. (“FEPA”) and R.I. Gen. Law § 42-112-1 et seq. (“RICRA”).
160. Plaintiff engaged in protected conduct, opposed unlawful conduct, and exercised his rights
under the ADA, FEPA, and RICRA, by reporting harassment and discriminatory treatment
because of perceived disability to Greenleaf leadership.
161. As a result of Plaintiff’s protected activity, Plaintiff was subjected to disparate treatment and
harassment which changed the terms and conditions of his employment as stated above.
162. Defendant’s agents knew of the retaliatory conduct but failed to take swift, remedial action to
20

remedy it in violation of, inter alia, the ADA, FEPA, and RICRA.
163. Plaintiff was terminated because of – and extremely proximate to – his formal complaints of
harassment and discrimination because of perceived disability related to needing a lung biopsy.
motivated by animus, impermissible and unlawful considerations, which violate, inter alia,
ADA, FEPA, and RICRA.
Superior.
COUNT FIVE
RETALIATORY DISCRIMINATION
RETALIATORY DISCHARGE
Violation of the Rhode Island Whistleblowers’ Protection Act (WPA), R.I. Gen. Law § 28-50-
1, et seq.
170. Plaintiff was afforded protections from retaliatory harassment, discrimination and termination
because of taking part in a protected activity under the WPA.
171. The WPA defines an employer as “any person…corporation or other business entity”; thus, both
Dr. Bock, as the majority owner, and Greenleaf were Plaintiff’s employer.
172. Plaintiff engaged in protected conduct under the WPA when he reported what he reasonably
believed to be violations of law to his supervisor, Dr. Seth Bock, related to co-owner Mr.
21

Radebach’s self-dealing, breach of fiduciary duties, conflicts of interest, funds
misappropriation, intermingling, and his involvement in Mr. Cohen’s apparent plan to deceive
the IRS auditor.
173. Plaintiff engaged in protected conduct when he refused to comply with Mr. Cohen’s and Mr.
Radebach’s requests related to misleading the IRS.
174. As a result of Plaintiff’s protected activity, Plaintiff was subjected to retaliatory harassment
and discrimination by Defendant’s agents.
175. Plaintiff was terminated in retaliation for these protected acts.
motivated by animus, impermissible and unlawful considerations and violate, inter alia, WPA.
Superior.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays that this Court:
a. Order judgment for Plaintiff against Defendant on all Counts of the Complaint and declare that
the practices detailed in this Complaint are unlawful;
b. Order, for all applicable Counts, that Defendant make Plaintiff whole by awarding appropriate
back pay with interest, front pay, compensation for all other lost income and benefits, earning
capacity, and all other relevant entitlements and emoluments;
22

c. Order, for all applicable Counts, that Plaintiff be awarded an amount of money which will fairly
compensate his mental anguish, emotional pain and suffering, damage to his reputation, loss of
standing in the community, and other damages incurred;
d. Order, for all applicable Counts, that the Defendant pay Plaintiff’s costs and reasonable
attorney’s fees resulting from this action;
e. Order, for all applicable Counts, that the Defendant pay punitive or exemplary damages, as
appropriate to punish Defendant for its malicious conduct, recklessness conduct, and/or callous
indifference to the statutorily and common law protected rights of Plaintiff;
f. Order, for all applicable Counts, that Defendant pay post-judgment interest and pre-judgment
interest, including interest for all damages awarded to Plaintiff from the date the cause of action
accrued, where appropriate and allowable by law;
g. Retain jurisdiction of this action to ensure full compliance; and
h. Order, for all Counts, such other relief to Plaintiff as this Court deems just and proper.
DEMAND FOR JURY TRIAL
PLAINTIFF DEMANDS A TRIAL BY JURY ON ALL ISSUES SO TRIABLE
September 16, 2020

Respectfully Submitted by Plaintiff,
JEFFERY DIEFFENBACH
By his attorney,
_/s/ Paige Munro-Delotto__

Paige Munro-Delotto, Ph.D., Esq. #9291
Munro-Delotto Law, LLC
400 Westminster Street, Ste. 200
Providence, RI 02903
(401) 521-4529
(866) 593-9755 (fax)
Email: [email protected]
23

Case 1:20-cv-00413-MSM-PAS Document 1-1 Filed 09/16/20 Page 1 of 2 PageID #: 24
JS-44 (Rev. 6/13 RI) CIVIL COVER SHEET

I. (a) PLAINTIFFS DEFENDANTS
JEFFERY DIEFFENBACH GREENLEAF COMPASSIONATE CARE CENTER,
Newport
(b) County of Residence of First Listed Plaintiff __________________________ Newport
County of Residence of First Listed Defendant __________________________________________
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE
LAND INVOLVED.
(c) Attorney’s (Firm Name, Address, and Telephone Number)
Attorneys (If Known)
Paige Munro-Delotto, Esq. Munro-Delotto LLC,
400 Westminster St., Ste. 200
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only)
Admiralty Constitutional Law Environmental Law Miscellaneous Civil Cases Mass Torts
120 Marine (Other) 893 Environmental Matters Continued 360 Other Personal Injury
340 Marine(Injury to Immigration Products Liability
Seamen) 950 Constitutionality of 462 Naturalization App. 690 Other (Forfeiture/Penalty)
195 Contract Product
Admin/Agency Appeals Other State Statutes 465 Other Immigration
Liability
890 Other Statutory Actions 440 Other Civil Rights Actions 870 Taxes (U.S. Plaintiff or
245 Tort Product Liability
(APA Appeals, IDEA (Constitutionality of Defendant)
871 IRS-Third Party (26 315 Airplane Product
Appeals, Other) Federal Statues) Indian Law
Liability
Elections and Voting 890 Other Statutory Actions U.S.C. § 7609)
345 Marine Product
Bankruptcy 890 Other Statutory Actions
Liability
422 Appeal 28 U.S.C. § 158 Insurance 891 Agricultural Acts
110 Insurance Contract 355 Motor Vehicle
423 Withdrawal 28 U.S.C. § 400 State 895 Freedom of Information
Product Liability
157 Reapportionment Act
365 Personal Injury
441 Voting Labor and Occupational 896 Other Statues: Arbitration
Product Liability
Civil Rights
Banks and Banking Safety 899 Other Statutes: Admin.

385 Property Damage
Other - Civil Rights Procedures Act/Review/
710 Fair Labor Standards Act Product Liability
Appeal of Agency Decision
Torts and Personal Injury

140 Negotiable Instruments 720 Labor/Management Professional Malpractice
Patents (Intellectual Property)
430 Banks and Banking 440 Other Civil Rights Relations Act 830 Patents 362 Personal Injury - Med.
443 Housing/ 740 Railway Labor Act Prisoner Petitions Malpractice
Accommodations 751 Labor: Family and HABEAS CORPUS Motor Vehicle
446 Americans with Medical Leave Act 463 Alien Detainee(Habeas) Accidents/Slip and Fall
Anti-trust Disabilities 790 Other Labor Litigation 510 Motions to Vacate 350 Motor Vehicles
448 Civil Rights- Sentence (Habeas) 360 Other Personal Injury
410 Anti-Trust Education Other Torts and Personal
530 General (Habeas)
Miscellaneous Civil Cases 535 Death Penalty (Habeas) Injury incl. Asbestos cases
Construction Contracts Copyright & Trademark 150 Recovery of OTHER
(Intellectual Property) Overpayment and 540 Mandamus and Other 310 Airplane
820 Copyright 550 Civil Rights (1983) 320 Assault, Libel and
130 Miller Act Enforcement of Judgment
840 Trademark 555 Prison Conditions(1983) Slander
190 Other Contracts (Collections)
Employment 151 Medicare Act 560 Civil Detainee-Cond. of 330 Federal Employers’
Business and Commercial
Securities Law & Discrimination 152 Recovery of Defaulted Liability

Confinement
Stockholder Suits Student Loans (excluding Real and Personal Property 360 Other Personal Injury
Employment and Employee Benefits
160 Stockholders’ Suits 442 Employment (Fed. Tort Claims Act)

Veterans) 210 Land Condemnation
850 Securities/ 445 Americans with 360 Other Personal Injury
153 Recovery of 220 Foreclosure
Commodities/ Disabilities-
Overpayment of 230 Rent, Lease and 367 Personal Injury:
Exchange Employment HealthCare/Pharmaceutical
Veterans’ Benefits Ejectment
440 Other -Civil Rights Personal Injury Product
370 Other Fraud 240 Torts to Land
375 Other Statutes: False 290 All other Real Property Liability
Other - Business/Comm. ERISA 368 Asbestos Personal
Claims Act 380 Other Personal Property
440 Other Civil Rights Damage Injury
196 Franchise
490 Cable/Satellite TV 791 Employment Ret. (Immigration/Deportation) RICO
Inc. Security Act 450 Commerce 470 RICO
Consumer Credit 460 Deportation Social Security
190 Other Contracts Other Employment 625 Drug related seizure of 861 HIA (1395ff)
371 Truth in Lending Benefits property 862 Black Lung (923)
480 Consumer Credit 863 DIWC/DIWW (405(g))
190 Other - Contract CONTINUED 864 SSID Title XVI
442 Other - 865 RSI (405(g))
Employment
ON
REVERSE SIDE
V. ORIGIN (Place an “X” In One Box Only)
1 2 3 4 5 6 7
Original Removed from Remanded from Reinstated or Transferred from Multidistrict Appeal to District Judge
Proceeding State Court Appellate Court Reopened another district Litigation From Magistrate Judgment
(Specify)
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
29 U.S.C. § 623(a) and § 623(d) (“ADEA”), 42 U.S.C. §§ 12112, 12203 (“ADA”)

VI. CAUSE OF ACTION
Brief description of cause:
Age / Perceived Disability Harassment, Discrimination, and Retaliation
VII. REQUESTED IN Check if this is a Class Action DEMAND $ JURY DEMAND: Yes No
COMPLAINT Under F.R.C.P. 23 (Check YES only if demanded in complaint)
VIII. RELATED CASE(S)

IF ANY JUDGE _________________________________________ DOCKET NUMBER _______________________________
Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form.
September 16, 2020

____________________________________________________
/s/ Paige Munro-Delotto
_________________________________________________________________
Date Signature of Attorney of Record
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44

Authority for Civil Cover Sheet
The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleadings or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk
of Court for the purpose of initiating the civil docket sheet. Consequently a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed. Listed below
are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the Cover Sheet.
I. COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: For each civil case filed, except U.S. plaintiff
cases, enter the name of the county where the first listed plaintiff resides at the time of filing. In U.S. plaintiff cases, enter the name of the county in
which the first listed defendant resides at the time of filing. (NOTE: In land condemnation cases, the county of residence of the “defendant” is the
location of the tract of land involved.)
III. CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction under
Section II.
IV. NATURE OF SUIT: Place an X in the appropriate box. Make sure to select the Nature of Suit from the category which best describes the primary cause
of action found in your complaint. You must select only one nature of suit.
VIII. RELATED CASES, IF ANY: This section of the JS-44 is used to reference related pending cases if any. If there are related pending cases, insert the
docket numbers and the corresponding judge names for such cases.
FOR OFFICE USE ONLY
Receipt # ____________ Amount ____________ Applying IFP ___________ Judge _____________________ Mag. Judge _________________
AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT

for the
DistrictDistrict
__________ of Rhode Island
of __________
JEFFERY DIEFFENBACH )
)
)
)
Plaintiff(s) )
)
v. Civil Action No. 1:20-cv-00413
)
GREENLEAF COMPASSIONATE CARE CENTER, )
INC., )
)
)
Defendant(s) )
SUMMONS IN A CIVIL ACTION
To: (Defendant’s name and address) GREENLEAF COMPASSIONATE CARE CENTER, INC.
C/O DR. SETH BOCK
1637 WEST MAIN ROAD PO BOX 118
PORTSMOUTH, RI 02871
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are: Paige Munro-Delotto Ph.D., Esq.
Munro-Delotto Law, LLC
400 Westminster Street, Ste. 200
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No. 1:20-cv-00413
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)

was received by me on (date) .
u I personally served the summons on the individual at (place)

on (date) ; or
u I left the summons at the individual’s residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individual’s last known address; or
u I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
u I returned the summons unexecuted because ; or
u Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:

JEFFERY DIEFFENBACH v. GREENLEAF COMPASSIONATE CARE CENTER, INC.

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Case 1:20-cv-00413-MSM-PAS Document 1 Filed 09/16/20 Page 1 of 23 PageID #: 1

UNITED STATES DISTRICT COURT FOR

v. PLAINTIFF DEMANDS A TRIAL BY JURY

This action is commenced by JEFFERY DIEFFENBACH (hereinafter “Plaintiff”)

against GREENLEAF COMPASSIONATE CARE CENTER, INC. (hereinafter “Employer,”

JURISDICTION AND VENUE

the judicial district of this Court.

Equal Employment Opportunity Commission (EEOC).

a private civil action to be filed.

inactive CPA accountant with a long and impressive job history.

Independent Contractor for Defendant, a medical marijuana licensed dispensary in Portsmouth,

RI, to do bookkeeping, QuickBooks maintenance, bank reconciliations, tax planning, budgeting,

cash flow analysis, and eventually compliance and payroll.

their ownership interests are 55% and 45% respectively.

RIGL 7-6-1 et seq.

and all of leadership’s fiduciary duty to the entity of Greenleaf.

dispensary, Alternative Compassion Services, Inc. in Bridgewater, MA.

businesses including his financial involvement.

breach of his employment agreement because of running a competing business.

due to the time spent in his other businesses.

attorney and that a Compensation Committee be established.

expressed concerns about these events to Dr. Bock.

percentages upon information and belief, of 50% and 50% respectively.

Credit Union bank account.

camera as proof of Mr. Radebach’s confrontation in the parking lot.

threatened or harassed, so it was an extremely uncomfortable situation at work for Plaintiff.

finances, despite Mr. Radebach’s threats, at the behest of Dr. Bock.

who could perform a forensic audit of GVC.

Company, running payroll and accounting.

employed, and to replace him, after termination.

that Plaintiff did not believe was correct.

56. Plaintiff refused to comply with these requests.

59. Plaintiff reported these concerns to Dr. Bock.

distributions to directors or officers, and requires reasonable compensation for services

situation due to pressure to mislead the IRS regarding the audit.

Plaintiff perceived as misleading the IRS agent.

Napolitano, Chief Operating Officer (hereinafter “Ms. Napolitano”).

as well as due to his advanced age and perceived medical conditions.

his antiquated record keeping and manual time keeping procedures.

employment with Greenleaf was the overseeing of payroll.

health at that time.

Ms. Desjarlais would not provide any more information.

requiring a lung biopsy.

others including Ms. Napolitano and Mr. Carlone.

degrade Plaintiff before other leaders.

sick, thus incapable of doing his job.

healthy and could do his hob.

on Mr. Radebach’s personal Visa Card.

103. Ms. Napolitano responded, “well that’s new information.”

needed to do his remaining work, such as preparing taxes, was blocked.

law by Mr. Radebach.

needed to talk to him.

investigation into Plaintiffs allegations of harassment/discrimination and violation of the

protections provided by the Whistleblower Act.

conditions (i.e. perceived disability).

disability harassment and discrimination.

a Rhode Island licensed attorney2.

resulted in causing Plaintiff emotional distress, humiliation, and other damages.

organizational chart submitted to at least one prospective buyer in due diligence.

caused Plaintiff additional and ongoing distress and damages.

ADEA, FEPA, and RICRA.

FEPA, and RICRA.

intentionally discriminatory, motivated by animus, impermissible and unlawful considerations

Citizen or Subject of a 3 3 Foreign Nation 6 6

Banks and Banking Safety 899 Other Statutes: Admin.

Securities Law & Discrimination 152 Recovery of Defaulted Liability

160 Stockholders’ Suits 442 Employment (Fed. Tort Claims Act)