LANDYA B. MCCAFFERTY, District Judge.

Now Comes the Plaintiff, Sanjeev Lath in the matter, and submits his Fourth Amended Complaint pursuant to this Honorable Court's order dated July 13, 2017 [Doc 170].

Claim 16 against Gerard Dufresne, Betty Mullen, Oak Brook Condominium Owners' Association, thru its present and past board members and employees, for conspiracy to cause constructive eviction of Plaintiff from his residence and conspiracy to deprive Sanjeev Lath of basic necessities such as safe drinking water, physical safety and proper sanitary conditions by interfering, coercing and intimidating Lath in violation of Fair Housing Act

1. Defendant Gerard Dufresne and past/present members of the board, Perry Vallee, Warren Mills and resident Betty Mullen using their influence, authority and fiduciary offices and with or without the help of various city departments such as the Police Department, Planning and community Development, Health Department, Water Works, Sewage, Public Works and Code enforcement in a concerted effort and in order to cause constructive eviction of Plaintiff Sanjeev Lath, not once but on two separate occasions thru imposition of frivolous fines, impounding frivolous violation notices and citations, invasion of Lath's privacy in the seclusion of his home and in particular Lath's bathroom, selective enforcement of laws and rules, participating in violent acts in order to cause bodily harm upon Lath, his friends and family members, intercepting and/or eaves dropping on privileged communications and relay contents of such communication to third parties, in order to slander or defame Lath or cause harm upon Lath's character, denial of services promised upon Lath by the bylaws and declaration such as master policy coverage during a casualty, repair of deck, and enjoyment of clubhouse facilities, by making repeated and incessant complaints to authorities to cause unjust convictions, interfering in contractual relations that Lath has with third parties such as Amica, Comcast, Mental Health Center of Greater Manchester, Dept. of Water Works, his doctors, lawyers, therapists and Eversource. As a result of such overt acts by the said defendants, Lath has been compelled to surrender possession of his home temporarily whereby the premises have been in both occasions rendered unfit for human habitation, in whole or in part.

2. Lath believes and on that basis, alleges that Defendants' worked tirelessly around the clock to commit Lath to a mental institution such as the Elliot Hospital Psych Center and New Hampshire Hospital by asserting Lath as "deranged" and having "suicidal tendencies" and Lath acting "similar to the subject who murdered the reporter on the North End of Manchester." Defendants in a concerted effort acting as a symphony group in orchestra discussed that Lath was "not good to have in the building", alleged Lath of slamming his door and banging on the wall, and eavesdropped upon Lath's privileged communications with his doctors and therapists in order to spy upon which medication was Lath and keep a whereabouts of Lath's doctor's visits. Defendants believed that Lath was on "welfare" and were "mad" because of his disability and refused to "look at him . . .go near him or touch him in any way." Defendants used Lath's medical information from his reasonable accommodation's request, to pass derogatory comments such as that Lath sounded "like he's in his way to becoming possessed" and the reason why Lath is "flaring like hemorrhoids" is because Lath's medications changed.

3. Defendants imposed frivolous violation notices and fines upon Lath when Lath refused to provide a copy of his house keys to the Defendants, even after Lath was assaulted by Defendants' employee, who had unfettered access to Lath's unit. Lath while exercising his right to enjoy the terms, conditions, services of the dwelling, free from any harassment was subjected to frivolous fines and notices, which the defendants charged Lath's account. Such repairs were for damages which Lath has not caused, such as the water pipe breaking for lack of preventive maintenance or replacement, which may have caused the sewage to be backed up or leak into the drinking water.

4. Defendants in a concerted effort to cause Lath mental and physical harm or cause Lath to harm himself carved a recess from the unit under his unit that looked into Lath's kitchen and bathroom.

5. Defendants constructively denied services upon Lath, which were regularly provided to other unit owners, such as "bleeding" of pipes, usage of clubhouse services such as tennis court, gymnasium and sauna, issuing invoices/receipts for payments of common assessments, voting and casting ballots, attendance to the Board meetings, insurance carrier information for the master policy, repair to his deck and patio and interfering with contractors which Lath hired to perform services within his own unit.

6. Defendants refused to provide any insurance information to Lath after Lath's house was on fire and may have retained any moneys they received for any claims they filed against the master policy. Defendants interfered with Lath's mail by returning his IRS check as "undeliverable" which delayed repairs to his unit for which Lath had no choice but to live in his unit without electricity and water. Defendants rallied against Lath by making repeated calls to the Fire Department and Mental Health Center for Greater Manchester alleging Lath "making threats towards his neighbor and had been acting in a bizarre fashion in his apartment, allegedly smearing feces on the walls, writing notes with paranoid statements on the notes." Such repeated calls resulted Lath to be involuntarily admitted to a locked psychological facility.

7. Such damages and the repeated calls by the Defendants caused Lath to receive several violation notices from the various departments within the City of Manchester, such as the Police Department, Fire Department, Code enforcement, Health Department and Planning and community Development which deemed Lath's residence inhabitable which caused Lath to be constructively evicted from the unit he owns, in February 2017 and then again in July 2017.

8. Such actions of the said defendants may also have been a result of their intent to cause unjust convictions upon Lath by calling the Police Department alleging Lath of committing the crimes of criminal mischief and disorderly conduct by accusing Lath of vandalizing washers and dryers, burning a piece of cardboard, drilling holes in walls, kicking walls/doors and causing a fire in order to destroy evidence and harassing other residents "to a point of causing [their] illness and consequently her death." Defendants and each of them called the Attorney/agents for Lath's home owners' insurance, Michael Snyder and Peter Hilchey to relay details of Lath's private life and testified seeing Lath "barely clothed".

9. Defendants and each of them accused Lath of trespassing when Lath entered the club house and caused the act of assault upon Lath based upon such belief. Defendants prohibited Lath from attending annual meeting because Lath owed fines, and unlawfully appropriated the common assessment fee towards these frivolous fines, while other similarly situated residents were allowed to such meetings.

10.For such actions of the said defendants, Lath has been displaced from his residence for almost 9 (nine) months (270 days) where he hopped from couch to couch and hotel to hotel, at times without food and medications and with negative bank account which has caused his health to seriously deteriorate, for which Lath is entitled to compensatory damages and punitive damages in the amount of one million days for each day of his displacement.

11. Lath alleges that such actions of the said defendants were motivated by their animus towards Lath's disability of having a mental handicap, and for having filed three complaints with the Human Rights Commission, within a period of two years, for discrimination, retaliation and Defendants failure to provide an emotional support dog to Lath. Such harassments started within days of Lath filing his first complaint and were devised to "stop" Lath. Defendants have expressed their disagreements concerning these complaints to Manchester Police Department and before this Court during several hearings.

Lath respectfully requests that this Honorable Court grant Lath's Fourth Amended Complaint. Further Lath certifies that a copy of this Complaint has been emailed to Defendants' Attorneys thru this Court's ECF system and has been emailed to Jerry Dufresne via his email to