1. Plaintiff Rev. Thomas Coover ("Father Coover") resides at 51 ½ New York Street, Dover, New Hampshire and is a citizen thereof;

2. Based on information and belief, Defendant Roman Catholic Bishop of Manchester a/k/a Diocese of Manchester ("Diocese") is a non-profit corporation incorporated under the laws of the State of New Hampshire, doing business and owning property within the State of New Hampshire, specifically in Hillsborough County, and maintaining a principal and usual place of business at 153 Ash Street, Manchester, New Hampshire;

3. Based on information and belief, Defendant Bishop John B. McCormack ("Bishop McCormack") is a citizen of the State of New Hampshire and resides in Manchester, New Hampshire;

4. Based on information and belief, Defendant Rev. Edward J. Arsenault ("Father Arsenault") is a citizen of the State of New Hampshire and resides in Manchester, New Hampshire;

5. Plaintiff Father Thomas Coover was ordained as a Catholic Priest by Archbishop Francis Zayek on November 25, 1978;

6. In or around October 1997, Father Coover was offered the position of Full Time Chaplain of the Saint Ann Home in Dover, New Hampshire by Defendant Diocese;

7. Bishop Leo O'Neil, the Diocesan Bishop at the time that the Chaplain position was offered to Father Coover, approved Father Coover's appointment as Chaplain;

8. In or around September of 1998, Defendant Bishop McCormack was named Ordinary for the Defendant Diocese;

9. In or around September of 2000, Father Coover accepted an invitation by the Brady High School in Concord, New Hampshire to provide a priestly presence and to conduct Mass at the school;

10. In May of 2002, due to the abrupt removal of Father James A. "Seamus" MacCormack from Saint Patrick Parish in Jaffrey, New Hampshire, the Defendant Diocese requested that the Plaintiff Father Coover provide temporary pastoral coverage at Saint Patrick Parish;

11. In or about May 2002, Plaintiff Father Coover accepted appointment by the Defendant Diocese as temporary pastor of the Saint Patrick Parish in Jaffrey, New Hampshire;

12. Plaintiff Father Coover learned of hostility between Jaffrey Parishioners and Defendant McCormack at this time and communicated the same to Defendant Bishop McCormack;

13. Plaintiff Father Coover contacted the Defendant Diocese to arrange a meeting between the Bishop and members of the Pastoral Council to discuss the problems he perceived with the Jaffrey Parishioners;

14. In or about June of 2002, Defendant Diocese offered and the Plaintiff Father Coover accepted, permanent pastorship of Holy Trinity Church in Somersworth, New Hampshire and twinned Parish, Saint Mary Church in Rollingsford, New Hampshire;

15. During this time, the Plaintiff learned of incidents of sexual harassment of female staff of Saint Anne Nursing Home by superiors and reported his grave concerns of what was believed to be taking place to the Defendant Bishop McCormack;

16. Plaintiff Father Coover requested that Defendant Bishop McCormack visit the nursing home to restore faith of the community in the Bishop and Diocese, reminding the Bishop of his duties to the elderly and infirmed. The Bishop did not accept the invitation or otherwise respond to the Plaintiff's request;

17. In or about October of 2002, the Plaintiff Father Coover discovered large quantities of pornographic materials, guidebooks containing locations of homosexual meeting places nationwide and sexual attire including items consisting of leather and chains in multiple locations in the church rectory and garage;

18. Plaintiff Father Coover contacted the Diocese to disclose the discovery of such items and to request instruction as to how to proceed;

19. Defendant Father Arsenault, on behalf of Defendant Bishop McCormack and Defendant Diocese, instructed Plaintiff Father Coover to assemble the found items, place the items into a sealed container and deliver the container directly to the Chancery in Manchester, New Hampshire;

20. Plaintiff Father Coover delivered the found materials as instructed and was further instructed by Father Arsenault not to discuss the circumstances with anyone;

21. Plaintiff Father Coover continued to find materials of a homosexual and pornographic nature around the rectory and continued to communicate these discoveries to representatives of the Defendant Diocese;

22. In early 2004, Plaintiff Father Coover learned of personal and highly sensitive information relating to Defendant Bishop McCormack and Father Paul Shanley, from Boston, Massachusetts. In learning of this information, Plaintiff Father Coover conducted an independent investigation of the circumstances as they were related to him and discussed the claims and findings with a priest close to the Diocese: Father Steven Kucharski of Manchester, New Hampshire;

23. Not long after the discussion with Father Kucharski, On June 2, 2004, Defendant Father Arsenault, on behalf of Defendant Bishop McCormack and Defendant Diocese, summoned Plaintiff Father Coover to the Chancery to undertake a private meeting with Plaintiff supposedly to discuss an issue involving Bingo proceeds that were believed to have been stolen;

24. At this meeting, Defendant Father Arsenault accused Plaintiff Father Coover of stealing Bingo funds, of having engaged in inappropriate sexual conduct of his own and of threatened suicide, none of which were true and none of which did Defendant Arsenault then or thereafter have evidence of;

25. Following these accusations, Plaintiff Father Coover terminated the meeting despite Defendant Father Arsenault's insistence for the Plaintiff to remain, at which time the Plaintiff returned to the Church in Somersworth, New Hampshire;

26. Shortly after 2:00 p.m. on June 2, 2004, a Somersworth, New Hampshire Police Officer appeared at Plaintiff Father Coover's residence on High Street in Somersworth, New Hampshire and placed Plaintiff Father Coover in handcuffs. The Officer claimed to have been responding to representations and statements made by Defendant Father Arsenault;

27. The Somersworth Police Officer took Plaintiff Father Coover into custody and transported him to the Wentworth-Douglass Hospital ("WDH") in Dover, New Hampshire against his will where he was then transferred to Concord State Hospital ("CSH") and remained in custody involuntarily for seven days awaiting official court proceedings to determine his release;

28. During Plaintiff Father Coover's detention at WDH and CSH, Defendant Father Arsenault directed individuals to search the Plaintiff's private living quarters in Somersworth, New Hampshire;

29. Based on understanding and belief, Plaintiff Father Coover's retention at WDH and CSH was based solely on statements made by Defendant Father Arsenault both to the Somersworth Police Department and to staff of WDH and CSH directly;

30. Based on understanding and belief, after Plaintiff Father Coover arrived at WDH and was about to be released, Defendant Father Arsenault again contacted staff members of WDH and insisted that the Plaintiff remain detained;

31. Several days later, official administrative proceedings provided that Plaintiff Father Coover was not properly detained and was ordered to be released from custody;

32. Based on information and belief, during Plaintiff Father Coover's detention, Defendant Father Arsenault directed a licensed medical doctor (Karen Lauze, M.D.) ("Dr. Lauze") of the Diocese "Parish Council" to present to WDH and to represent herself as Plaintiff Father Coover's personal physician for the purposes of accessing private health care information about the Plaintiff Father Coover;

33. Dr. Lauze neither had the status of Plaintiff Father Coover's physician nor had ever rendered medical treatment to the Plaintiff in the past;

34. Private health care information relating to Plaintiff Father Coover's care, physical and mental condition was in fact released to Dr. Lauze and the same information was related by the Defendant Diocese to parishioners in Somersworth, New Hampshire;

35. Following Plaintiff Father Coover's release from the hospital and return to the Somersworth Parish, Defendant Father Arsenault insisted that Plaintiff Father Coover evacuate the rectory within twenty four hours;

36. Plaintiff Father Coover did abandon the rectory as requested and filed paperwork with the Somersworth Branch of the United States Post Office for mail to be forwarded to a new address. Despite this filing, Defendant Father Arsenault directed all of Plaintiff, Father Coover's, personal mail to be forwarded to him at the Chancery Office in Manchester, New Hampshire;

37. Defendant Diocese through the actions of Defendant Father Arsenault withheld past salaries of Plaintiff Father Coover unless the Plaintiff agreed to resign, to which Plaintiff Father Coover agreed;

38. In or around August of 2004, Plaintiff Father Coover responded to a letter written by Defendant Father Arsenault, wherein Plaintiff Father Coover therein referred to incidents relating to Defendant Bishop McCormack;

39. In around August of 2004, Defendant Bishop McCormack withdrew Plaintiff Father Coover's faculties to function in the Dioceses of Manchester. Based on this withdrawal and statements originating from the Defendants, Plaintiff Father Coover's personal Ordinary thereafter withdrew all necessary faculties for Plaintiff Father Coover to function as a priest in any other Diocese worldwide. These faculties will remain withdrawn until resolution of issues with the Defendant Diocese.

40. The Defendant Diocese has provided no reason for withdrawal of faculties, disclosure of reasons for withdrawal of faculties or provision for reinstatement of faculties.

41. Thereafter, Defendant Father Arsenault, made false statements to Plaintiff Father Coover's employer, Youth Development Center ("YDC") of Manchester, New Hampshire and was placed on administrative suspension, ultimately resulting in Plaintiff Father Coover's resignation;

42. Based on information and belief, the administrative suspension resulted solely from false and misleading statements made by Defendant Father Arsenault to staff members of the YDC;

43. Defendant Diocese, Defendant Bishop McCormack and Defendant Father Arsenault placed arbitrary restrictions on Plaintiff Father Coover's access to parishioners in jurisdictions in which Plaintiff Father Coover had previously maintained pastoral practices;

44. Defendant Diocese, Defendant Bishop McCormack and Defendant Father Arsenault failed to follow its own standards and protocols relating to the foregoing circumstances mentioned in this Complaint with respect to investigation and disclosure of circumstances leading to the Plaintiff's discharge and the Defendants' withdrawal of faculties;

45. As a direct result of the Defendants' actions, Plaintiff Thomas Coover has suffered irreparable harm to his reputation, severe emotional distress, lost earnings and lost earning capacity, involuntary incarceration and evaluation, personal embarrassment and public disclosure of private medical, psychological and emotional information protected by federal and state law, unlawful coercion, manifestation of physical injuries, substantial hardship, the inability to practice as a Catholic Priest and other losses.

46. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

47. The Defendants and/or their agents, employees and/or servants failed to exercise reasonable care and/or acted maliciously in publishing false and defamatory statements or facts about the Plaintiff to a third party on at least one occasion;

48. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

49. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

50. The Defendants and/or their agents, employees and/or servants, did make representations that were false, highly offensive to a reasonable person, with knowledge of their falsity or made in reckless disregard as to their truth and/or falsity, publicly, causing the Plaintiff injury.

51. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

52. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

53. The Defendants and/or their agents, employees and/or servants, did publicly disclose private and personal facts about the Plaintiff, causing him injury.

54. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

55. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

56. The Defendants and/or their agents, employees and/or servants, did directly, deliberately and illegally intrude into the Plaintiff's physical and mental solitude and seclusion including into private conversations, which caused the Plaintiff injury.

57. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

58. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

59. The Defendants, and/or their agents, employees and/or servants, did cause the Plaintiff severe emotional distress by breaching a duty owed to the Plaintiff.

60. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

61. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

62. The Defendants, and/or their agents, employees and/or servants, by extreme and outrageous conduct intentionally or recklessly caused the Plaintiff severe emotional distress.

63. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

64. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

65. The Defendants and/or their agents, employees and/or servants, did intentionally interfere with a contractual relationship between the Plaintiff and his employer, Youth Development Center of Manchester, New Hampshire. The Defendants' actions directly caused injury to the Plaintiff.

66. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

67. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

68. The Defendants and/or their agents, employees and/or servants, did actually and constructively discharge the Plaintiff in bad faith, based on retaliation and/or malice for performing or refusing to act as public policy would encourage and dictate. As a direct result of these actions, the Plaintiff suffered injury.

69. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

70. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

71. The Defendants, through their agents and acting in the authority and scope of their employment, did falsely imprison the Plaintiff for a period exceeding 72 hours against the Plaintiff's will and at the direction of the Defendants. As a direct result, the Plaintiff suffered injury.

72. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

73. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

74. That the Defendants, their agent, employees and/or servants made representations to employees and staff of WDH that Karen Lauze, M.D. was the personal physician of the Plaintiff for the purposes of obtaining private and protected information of the Plaintiff, that Karen Lauze, M.D. was not the personal physician of the Plaintiff, that this was known to the Defendants and to Karen Lauze, M.D., that medical staff of WDH did justifiably rely on the statements of Karen Lauze, M.D., and that the Plaintiff suffered irreparable harm as a result.

75. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.

76. The Plaintiff realleges all previous paragraphs as though fully set forth herein;

77. The Defendants, their agents, employees and/or servants, entered into a contract with the Plaintiff and breached that contract by constructively discharging the Plaintiff from his position for which he seeks damages.

78. The Plaintiff seeks damages in an amount greater than the minimum jurisdictional amount of this Court and less than the maximum jurisdictional limit of this Court.