PUC Lawsuit Complaint

DISTRICT COURT, CITY AND COUNTY OF
DENVER
1437 Bannock Street DATE FILED: July 6, 2022 1:46 PM
Denver, Colorado FILING ID: E717308B84E34
CASE NUMBER: 2022CV31883
FIONA SIGALLA COURT USE ONLY

Plaintiff
v.
ROBIN Z. MEIDHOF; PAUL KYED
Defendants
Attorney or Party Without Attorney (Name and Case Number:

Address): Division Courtroom
Samuel M. Ventola, #18030
Ventola Law
1775 Sherman Street, Suite 1650
Denver, Colorado 80203
Phone Number: (303) 864-9797
E-mail: [email protected]
_ ____________________________________________________________________________
COMPLAINT AND JURY DEMAND
Plaintiff for her Complaint against the Defendants states:
PARTIES
1. Plaintiff is an individual resident in Colorado.
2. Defendants are individual Colorado residents employed by the Colorado Attorney
General’s Office
JURISDICTION
3. This matter concerns actions directed at the Plaintiff by Defendants in this District.
4. Each of the Defendants acted in this State, and have done business related to this
action in this Jurisdiction.

5. This Court has personal jurisdiction over the parties to this action, as each of the
Defendants has transacted business in Colorado, and has taken the tortious actions described
below against Plaintiff in Colorado, and knowing that Plaintiff was a resident of.
VENUE
6. The claims herein concern torts committed against the Plaintiff, including tortious
actions in this District.
7. Venue is proper over all claims in this District.
STATEMENT OF FACTS
8. On July 9, 2021, Defendant Meidhof issued a letter to Plaintiff’s employer, the
Colorado Public Utilities Commission, containing several false and defamatory statements.
Upon information and belief, the source for all or substantially all of the information was
provided by Mr. Kyed.
9. Among the false and defamatory statements were the following:
a. That Ms. Sigalla had engaged in “unacceptable conduct and unprofessional
behavior.”
b. That the Attorney General’s Office “has previously raised concerns with Ms.
Sigalla’s behavior to Ms. Sigalla and her managers (e.g., 2017, 2018, 2019 and again
more formally in 2020).”
c. That “Ms. Sigalla has demonstrated and continues to engage in unacceptable
bullying and unprofessional behavior that has created a toxic workplace environment for
the PUC litigation team within the Colorado Attorney General’s Office This team
includes managers (First AAGs), senior and junior Assistant Attorney Generals (AAGs),
and support staff (both paralegals and administrative assistants), all of whom have
experience the impact of the abusive behavior by Ms. Sigalla.”
d. That “Ms. Sigalla’s unprofessional behavior includes, but is not limited to:
written and verbal communications that publicly ridicule or berate our attorneys; actions
before or during litigated proceedings that have undermined our legal guidance or work
product; and actions that otherwise have interfered with our office’s ability to provide
effective legal services to Trial Staff of the PUC (and, ultimately, to the People of the
State of Colorado.”
e. That “Ms. Sigalla’s overly aggressive and unprofessional approach to the
litigation process requires PUC Litigation team attorneys to expend a disproportionate
and unnecessary amount of time on her portions of proceedings (e.g., spending entire
meetings insisting on relatively minor edits to pleadings and insisting on unreasonable
positions in settlement discussions that distract both time and energy from attention to
other witnesses and other proceedings.)”
f. That “[a]s a result of the behavior, communications, and actions taken by Ms.
Sigalla, AAGs have been reduced to tears, senior AAGs have refused (or seriously
considered refusing) to work on matters in which Ms. Sigalla is a witness, and other
AAGs have determined the only viable option for a productive and positive work
environment was to seek employment outside the AGs office. PUC Litigation team
members are currently experiencing physical manifestations of anxiety and stress with
every written communication and interaction with Ms. Sigalla.”
g. That “Ms. Sigalla’s behavior has had an immediate and unacceptable impact
on the mental health and well-being of the PUC Litigation team, including attorneys who
have left the Office of the Colorado Attorney General after experiencing the behavior
described above.”
10. Following the July 9, 2021 letter, Defendants continued to engage in conduct hostile
to Ms. Sigalla, including refusing to provide service to Ms. Sigalla, interfering with her ability to
do her job, refusal to issue Ms. Sigalla’s discovery, refused to make legal filings requested by
Ms. Sigalla, excusing Ms. Sigalla from a hearing without authorization, undermining Ms.
Sigalla’s leadership of meetings, and asking that a member of Ms. Sigalla’s team to not share
information with her.
11. Defendants’ actions were wanton and willful and were taken in order to attempt to
have Ms. Sigalla’s employment terminated, and to damage Ms. Sigalla personally and
professionally.
12. All conditions precedent to the maintenance of this action have been satisfied. Ms.
Sigalla issued a timely notice of this claim pursuant to C.R.S. Section 24-10-109. No response
was provided.
FIRST CLAIM FOR RELIEF
(Defamation)
13. Plaintiff incorporates the foregoing paragraphs as if set out herein.
14. Defendants repeatedly published the false statements, orally and in writing, to third
persons not the Plaintiff, and, based on Plaintiff’s information and belief, continue to be
published by Defendants to various third parties.

15. The statements were published by the Defendants with knowledge same were untrue,
or with willful indifference as to the truth or falsity of the statements, and with the intent to do
serious injury to the Plaintiff personally and professionally.
16. Upon receiving notice, Ms. Sigalla denied said allegations and requested a retraction
of the allegations, which retraction has been denied.
17. The statements published were directed at the professionalism, ethics, and actions of
the Plaintiff and allege professional misconduct. In addition, the statements include allegations of
criminal and/or unethical behavior by the Plaintiff in her profession, with the purpose of injuring
Plaintiff.
18. The statements caused the Plaintiff irreparable harm and damage, and constitute libel
and slander per se and per quod.
19. Each of the Defendants, to whom each of the above statements were published,
ratified the statements and the conspiracy by a) failing to inform the Plaintiff of the actions, and
b) allowing the Defendant Corporations to publish such statements through one or more of its
Officers.
SECOND CLAIM FOR RELIEF

(Interference with Contract / Prospective Economic Advantage)
20. Plaintiff incorporates the foregoing paragraphs as if set out herein.
21. Plaintiff had an agreement with the Colorado Public Utilities Commission to act as
its employee.
22. The Defendants knew or reasonably should have known of the agreement.
23. The Defendants by words or conduct, or both, intentionally interfered with Plaintiff’s
contract and interfered with Plaintiff’s prospective economic advantage.

24. Defendants’ interference was caused by a personal animus against Plaintiff and a
desire to interfere with her contractual relations and prospective economic advantage.
25. Defendants’ interference with the agreement and Plaintiff’s prospective economic
advantage was improper.
26. Defendants’ interference caused Plaintiff damages.
PLAINTIFF DEMANDS A TRIAL BY JURY ON ALL CLAIMS SO TRIABLE.
Respectfully submitted this 6th day of July, 2022.
Original retained in the offices of

undersigned:
/s/ Samuel M. Ventola ____

Samuel M. Ventola . 18030
1775 Sherman St. #1650
Denver, Colorado 80203
Telephone Number: (303) 864-9797
Fax Number: (303) 496-6161
Email: [email protected]

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DISTRICT COURT, CITY AND COUNTY OF

FIONA SIGALLA COURT USE ONLY

Attorney or Party Without Attorney (Name and Case Number:

Plaintiff for her Complaint against the Defendants states:

1. Plaintiff is an individual resident in Colorado.

2. Defendants are individual Colorado residents employed by the Colorado Attorney

action in this Jurisdiction.

actions in this District.

7. Venue is proper over all claims in this District.

8. On July 9, 2021, Defendant Meidhof issued a letter to Plaintiff’s employer, the

provided by Mr. Kyed.

9. Among the false and defamatory statements were the following:

a. That Ms. Sigalla had engaged in “unacceptable conduct and unprofessional

more formally in 2020).”

c. That “Ms. Sigalla has demonstrated and continues to engage in unacceptable

experience the impact of the abusive behavior by Ms. Sigalla.”

e. That “Ms. Sigalla’s overly aggressive and unprofessional approach to the

litigation process requires PUC Litigation team attorneys to expend a disproportionate

meetings insisting on relatively minor edits to pleadings and insisting on unreasonable

other witnesses and other proceedings.)”

every written communication and interaction with Ms. Sigalla.”

information with her.

FIRST CLAIM FOR RELIEF

13. Plaintiff incorporates the foregoing paragraphs as if set out herein.

published by Defendants to various third parties.

serious injury to the Plaintiff personally and professionally.

of the allegations, which retraction has been denied.

and slander per se and per quod.

SECOND CLAIM FOR RELIEF

20. Plaintiff incorporates the foregoing paragraphs as if set out herein.

contract and interfered with Plaintiff’s prospective economic advantage.

advantage was improper.

26. Defendants’ interference caused Plaintiff damages.

PLAINTIFF DEMANDS A TRIAL BY JURY ON ALL CLAIMS SO TRIABLE.

Respectfully submitted this 6th day of July, 2022.

Original retained in the offices of

/s/ Samuel M. Ventola ____

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