health district complaint.1 The plaintiff filed an opposi-
tion to the motion to dismiss, arguing that, because
1
The plaintiff’s health district complaint stated: ‘‘Hello, I am currently an
employee at Midway Pizza in Groton CT. I am e-mailing you because I am
concerned for people’s health. I have spoken to my employer in regards to
these concerns and I’m afraid my voice has been ignored! There are so
many things at Midway Pizza that are not being done by proper code. I
would prefer this e-mail be anonymous, so that I will NOT lose my job. I
love my job and I love our customers. I just don’t like how things are
being done inappropriately. I have been informed by the owner Dimitrios
Lenoudias (a.k.a. Jimmy) and his brother Angelo Lenoudias that they have
‘FRIENDS THAT WORK INSIDE THE HEALTH DEPARTMENT’ which is
why they seem to get away with NOT FOLLOWING PROPER CODE! They
have said that this person/persons have made it possible for them to remain
up and running without consequence by TURNING A BLIND EYE TO THEIR
UNETHICAL PROCEDURES. There are many things to report so I will list
them one at a time! There is NOT ONE person currently at Midway Pizza
who is a certified safety food operator. There is a certificate on the wall
with a woman by the name of Hope Whitman on it. However, Hope Whitman
no longer works at Midway Pizza. In fact she has not worked there since
two maybe three weeks after I started and I started there three years ago
now. She is currently still on payroll to appear as though she still works
there. However, she is on the payroll due to helping the owner with his
bookkeeping. Not because she physically works behind the counter or even
with the food. There is NO GREASE TRAP in the kitchen at all. They had
it removed because it smelled terrible and it kept clogging, so now all the
grease runs right into the sewer. There is NO HAND WASHING SINK in the
front for us to be able to wash our hands. They had a sink in the front of
the store behind the counter, but it was not connected to a water inlet nor
did it have a drain connection. It was just a sink placed into the counter to
appear as though it had proper running water with a bucket placed under-
neath to catch any liquid that anyone had poured down the drain. We have
gloves, but we are told to only wear them when there is a customer in the
building, when we are wearing the gloves they prefer that instead of changing
them we use a rag to wipe/wash them. I get yelled at frequently because I
refuse to use the same gloves over and over. I have actually gotten screamed
at and lectured about how expensive one case of gloves are! I respond with,
it’s a small price to pay to see to it that no one gets ill. There is a RAT/
MOUSE PROBLEM! They have traps placed everywhere in the store. At
night you can hear them running across the ceiling tiles due to having a
drop ceiling. I have found oil bottles eaten into and instead of them throwing
the oil away, they saved it by pouring it into another receptacle. I have
found bags of spaghetti eaten into. Once more instead of throwing the
spaghetti away, they just throw out the broken pieces or eaten pieces. Only
once have they thrown the spaghetti away and that was only because I kept
explaining how mice/rats carry diseases and GOD forbid if someone were
to get sick. They have caught mice and have also caught rats. Whatever
they catch they kill by either stepping on them or drowning them. Both the
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