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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION

Bennie Kennedy, ) Breach of Contract,

 ) Fraud, 

Plaintiff, ) 

 ) 

) 

Vs. ) Case No.

 ) 

 ) 

Prairie State College, ) 

Individually and Collectively, ) 

 ) Misprision of Felony,

Prairie State College ) RICO/Relator

Board of Directors, ) 

Individually and Collectively, ) 

 ) 

Marie Hansel, ) 

Individually and Collectively, ) 

 ) 

Patty Valenziano, ) 

Individually and Collectively, ) 

 ) 

DOES 1-30, ) 

 ) 

 ) 

 Defendants. ) 

 

COMPLAINT

Bennie Kennedy, Plaintiff, by John H. Davis - Attorney for Plaintiff, (Indiana 

#4812-45), John H. Davis and Associates, 5201 Broadway Suites #203 and #205, 

Merrillville, Indiana 46410, (219) 884-2461; Mailing Address: John H. Davis - Attorney 

at Law, P.O. Box 43, Crown Point, Indiana 46308-0043. 

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Plaintiff, Bennie Kennedy, through his undersigned counsel for the complaint 

against Defendants, Prairie State College, individually and collectively, Prairie State 

College Board of Directors, individually and collectively, Marie Hansel, individually and 

collectively, Patty Valenziano, individually and collectively, and DOES 1-30 (DOES to be 

determined via discovery and/or litigation of this matter which will then be captioned as 

‘individually and collectively’). 

 

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PARTIES

1. Plaintiff(s): 

Plaintiff, Bennie Kennedy, (“Pl”), at all times relevant hereto is, and was, 

employed in the state of Indiana for Schneider Electric f/k/a Square D Company 

(“Schneider”) in their (“Schneider”) Crown Point, Indiana office. 

2. Defendant(s): 

2(a). Prairie State College, (“Prairie State”), at all times relevant hereto was a 

 regionally accredited college in the state of Illinois; 

2(b). Prairie State College Board of Directors, (“Board”), at all times relevant hereto 

 was the board of directors of the above stated Prairie State College in the state 

 of Illinois; 

2(c). Marie Hansel, (“Hansel”), at all times relevant hereto was employed by the 

 above stated Prairie State College, Prairie State Board of Directors in the 

 capacity of Academic Dean/Faculty (July/2010), subsequently promoted to 

 Interim Vice President of Academic Affairs and Dean of Faculty (July/2013) of 

 said college in the state of Illinois; 

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2(d). Patty Valenziano, (“Valenziano”), at all times relevant hereto was employed by 

 the above stated Prairie State College, Prairie State Board of Directors in the 

 capacity of Associate Dean (of) Faculty Affairs at Prairie State College in the 

 state of Illinois; 

2(e). DOES 1-30, to be determined as stated above, some of whom, it is believed, 

 were employed by the above stated Prairie State College/Prairie State College 

 Board of Directors. 

 

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PRELIMINARY STATEMENT

3. 

3(a). Bennie Kennedy, (“Pl”), was employed by “Prairie State” in a part-time capacity 

as an adjunct faculty instructor of accredited courses as well as non-accredited 

courses beginning the year 2004 to the year 2010 teaching the following courses: 

General Safety (Credited), Electrical Safety(Credited), OSHA 10 Hours-ARC Flash 

(Credited) & (Non-Credited), Industrial Electrical Maintenance (Credited), Confined 

Space Training (Non-Credited), Basic Electricity (Credited). 

3(b). Bennie Kennedy (“Pl”) learned unofficially – without termination procedures 

required by AIU (Adjunct Instructors Union) policy, that he (“Pl”) had been terminated as 

instructor/faculty from both accredited and non-accredited classes at “Prairie State” 

on or about December 2010. (See Copy of Prairie State College’s Adjunct 

Instructors Union (AIU) Policy marked as EXHIBIT 1 attached and made apart 

hereto).

3(c). Bennie Kennedy, “Pl”, subsequent to learning that he (“Pl”) had been terminated 

from teaching both accredited and non-accredited classes, that the decision to 

terminate him (“Pl”) had been made two (2) weeks prior to his (“Pl’s”) learning of his 

(“Pl’s”) termination. (See Copy of Email Dated 9/21/2010 at 11:30AM To: Georgia 

Karras and Marie Hansel From: Patty Valenziano@prairiestate.edu marked as 

EXHIBIT 2 attached and made apart hereto). (See Copy of Emails - Pages 4 

through 8 where Georgia Karras responded ‘Here should be all of the necessary 

credentials...’ marked as EXHIBIT 2). 

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EXHIBIT 2 clearly reflects that “Hansel” was concerned about a phone call from 

Square D company a/k/a Schneider Electric – Bennie Kennedy’s (“Pl’s”) employer which 

precipitated “Hansel’s” seeking reasons from other faculty and staff of “Prairie State” to 

terminate “Pl”, Bennie Kennedy. This action was being done, and continued, without 

the proper procedures under the contract for adjunct instructors. 

3(d). Plaintiff, Bennie Kennedy, upon the initial learning of his (“Pl”)’s termination of 

teaching both, accredited and non-accredited classes, began a series of 

communications via email to several faculty personnel as well as administrative 

personnel and union personnel to determine the reason for his (“Pl’s”) termination. (See 

Copies of Emails marked as EXHIBIT 3A attached and a made apart hereto). (See 

Copy of List/Table of Emails Ordered by Dates/Times for Identification marked as 

EXHIBIT 3B attached and a made apart hereto). 

3(e). Plaintiff, upon review of the union criteria, determined that the provisions 

contained in the union contract were not followed by Defendant, “Prairie State” and 

Prairie State “Board” regarding termination of union members/faculty. (See EXHIBIT 3B 

Email #16 Dated 01/04/2011). 

3(f). Plaintiff, approximately one (1) week prior to learning that his (“Pl”) employment 

as stated above was terminated, he (“Pl”) received a request from an individual seeking 

to take one (1) of his (“Pl”) classes and this individual said that he (Nic O’Donovan) 

needed permission from the instructor because the class was already filled. (See 

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Affidavit of Plaintiff marked as EXHIBIT 4 attached and made apart hereto). (See 

Copy of Email from Nic O’Donovan marked as EXHIBIT 5 attached and made apart 

hereto). 

3(g). Plaintiff, in response to several of the above mentioned email queries, was 

informed that there was a concern by administrators of “Prairie State” about a telephone 

call that had been received from Square D company a/k/a “Schneider” which came from 

their (“Schneider’s”) office in the state of Ohio. (See Copy of Deposition of Gloria 

Olson of Schneider Electric’s Ohio Office, Deposition Page 18 Line #9 – 

Submitted by Defendant Schneider Electric in their Motion For Summary 

Judgment as their EXHIBIT B in CAUSE NO: 2:12-cv-122-PRC marked as 

Plaintiff’s EXHIBIT 6 Page 6 of 13 Pages attached and made apart hereto). 

3(h). On or about February 27, 2014, the above mentioned Defendant, Marie Hansel 

(“Hansel”) authored a declaration under penalty of perjury that Bennie Kennedy (“Pl”) 

had been terminated and that declaration did not distinguish, or set forth, that Plaintiff’s 

(“Pl”)’s termination from teaching included both accredited and non-accredited classes, 

however, said declaration does infer that the termination was allegedly based on 

accreditation criteria which would be those accredited classes that plaintiff (“Pl”) had 

been, and was, teaching. (See Copy of Declaration of Defendant Marie Hansel – 

Submitted by Defendant Schneider Electric in their Motion For Summary 

Judgment as their EXHIBIT C in CAUSE NO: 2:12-cv-122-PRC marked as EXHIBIT 

7 attached and made apart hereto). 

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 This (“Hansel’s”) declaration allegedly setting forth the reasons for “Pl’s” 

termination comes four (4) years after “Pl’s” termination and said reasons for 

termination, to this date, have not been made available or directed to the adjunct 

instructor’s union at “Prairie State” nor has “Pl”, to date, been given the proper and 

contractual procedure for termination. Several emails represented in EXHIBIT 2 and 

also attached as EXHIBIT 3A & EXHIBIT 3B clearly reflect that “Pl” was not terminated 

because of lack of proper credentials. 

 This complaint was prepared after exhaustive review, research, and investigation 

regarding “Pl’s” termination and qualifications to teach courses – both credited and noncredited, at “Prairie State”. Additionally, “Pl” was found to be properly qualified to teach 

at “Prairie State” for six (6) years in both credited and non-credited classes prior to said 

phone call from Square D a/k/a Schneider Electric which referenced concerns about 

proprietary material being used. Plaintiff’s employer had an exchange regarding 

Plaintiff’s teaching classes outside of Square D or Schneider Electric and voiced no 

concerns about use of proprietary material outside of teaching/training at a competitor’s 

company. (See EXHIBIT 3B - Emails Numbered #2, #12, #1, AND #11). (See 

Affidavit of Plaintiff marked as EXHIBIT 4).

 Gloria Olson’s call to “Prairie State” was made under the direction of her (Gloria 

Olson’s) immediate supervisor who appeared to have an animus against “Pl”, in that, 

“Pl’s” reputation in the electronics field was growing exponentially which included 

authoring several articles published in nationally known electronic trade magazines. 

 This supervisor of Gloria Olson was an executive with Schneider Electric and 

was aware that Plaintiff had developed a direct ability to speak to the President of 

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Schneider Electric, therefore, it is the belief of Plaintiff that this executive was 

determined to cut down the reputation of Plaintiff and therefore was motivated to have a 

phone call made to “Prairie State”. (See Affidavit of Plaintiff marked as EXHIBIT 4). 

(See Copy of Deposition of Gloria Olson of Schneider Electric’s Ohio Office, 

Deposition Page 18 Line #9 and Deposition Page 19 Line #1 – Submitted by 

Defendant Schneider Electric in their Motion For Summary Judgment as their 

EXHIBIT B in CAUSE NO: 2:12-cv-122-PRC marked as EXHIBIT 6 Pages 6 through 

7 of 13 Pages). 

EXHIBIT 6, referenced above, sets forth the fact that a phone call was made to 

“Prairie State” in which said caller spoke directly to then ‘interim dean’, Marie Hansel 

(“Hansel”) on or about July-August 2010 which is the same timeframe that “Prairie 

State” asserts in Marie’s Hansel’s declaration under the penalty of perjury, that she 

(“Hansel”) and “Prairie State” became concerned about the teaching credentials or 

qualification of Plaintiff. Notwithstanding that such concern about qualifications had not 

been raised over the past six (6) years that Plaintiff had been teaching at “Prairie State”. 

And, again, was not a concern when the regional accreditation commission visited 

“Prairie State” to do a full re-accreditation. 

 Deponent, as indicated in EXHIBIT 6 (Deposition of Gloria Olson), Page 19 Line 

#1, sets forth that she (Olson) would have no clue as to what was, or could be, 

considered proprietary material of Schneider Electric - “I’m not a technical expert...”. 

 The above-stated Olson also indicated that she (Olson) spoke with the Interim 

Dean (“Hansel”) on her (Olson’s) first phone call to “Prairie State” and asked for a 

syllabus/curriculum reflecting classes being taught by Plaintiff, Bennie Kennedy and 

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subsequently contacted “Prairie State” on three additional occasions requesting to 

speak to the interim dean and was unable to speak with said interim – leaving 

messages and voicemails over the next two (2) to three (3) weeks. 

 Interim Dean “Hansel” sets forth that she (“Hansel”) was concerned about liability 

regarding “Prairie State” precipitated by the phone call she (“Hansel”) had received from 

Schneider Electric or Square D, yet she (“Hansel”) did not see fit to resolve the question 

of possible liability for “Prairie State” by sending the requested syllabus/curriculum 

reflecting classes taught by Plaintiff Bennie Kennedy. 

 The sworn declaration of “Hansel” is not only, clearly, ludicrous, disingenuous, 

and a complete deception and fraud on the Court in the case cited above, but it is an 

injury to the Plaintiff, Bennie Kennedy, in that, Bennie Kennedy has – to this date- been 

unable to get the procedures required by the adjunct instructors’ union (AIU) to resolve 

the reasons for his (“Pl’s”) termination. 

 

3(i). In the course of reviewing these facts by this office (Attorney John H. Davis & 

Associates), on behalf of Bennie Kennedy (“Pl”), research and examination of emails, 

documents, and statements compiled in the case of “Schneider” (Summary motion 

granted) were extensively reviewed which support a conclusion that the termination was 

not based on lack of proper credentials, in that, Bennie Kennedy (“Pl”) was also 

terminated from teaching non-accredited classes. 

 This office, in continuing an extensive review of the facts surrounding Plaintiff’s 

termination of teaching classes at “Prairie State”, this office (Attorney John H. Davis & 

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Associates) contacted and reviewed the regional accrediting body which accredited 

“Prairie State”. 

 It was determined that the regional accrediting body had performed a full 

accreditation review of “Prairie State” in 2008/2009 and reaffirmed their (“Prairie 

State’s”) accreditation which is held to be good for ten years from the point of this full 

accreditation review. (See Copy of Accreditation Document marked as EXHIBIT 8 

attached and made apart hereto). 

3(j). Plaintiff was hired by Defendant, “Prairie State” on or about 2004 to teach, both - 

accredited classes and non-accredited classes, and continued to teach accredited and 

non-accredited classes through the regional accreditation review which took place in 

2008/2009 and continued to teach said classes approximately two (2) years after the full 

accreditation review. 

3(k). Defendant, “Hansel”, in her (“Hansel’s”) capacity and responsibilities as Dean 

and later acting Interim Vice President, was not concerned about any faculty personnel 

not having proper teaching credentials or qualification (including Bennie Kennedy) in 

preparation for the visit of the regional accrediting team review. In her (“Hansel’s”) 

capacity, she (“Hansel”) had to be aware and prepared to accept the team’s (regional 

accrediting team) coming to “Prairie State” to do their (regional accrediting team) 

review. One of the criteria for such a review is reviewing the credentials of faculty 

teaching accredited classes. 

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 “Hansel’s” sworn declaration states that she (“Hansel”) received a phone call 

from Schneider Electric from their (“Schneider’s”) Ohio office. That “Hansel” states in 

her (“Hansel’s”) sworn declaration that she (“Hansel”) received said call in late-July 

2010 and then conducted a review of adjunct faculty in August 2010, however, did not 

appear to feel there was need to conduct such a review of adjunct faculty two (2) years 

prior to the regional accrediting review nor to do such a review two (2) years after the 

regional accrediting review. Marie Hansel (“Hansel”) actively participated in exchange 

of emails regarding a telephone call from “Schneider” as to Bennie Kennedy, (“Pl”). 

“Hansel” sets forth in one of said emails that she was concerned about the above 

referenced telephone call. And, it was also set forth in several emails that Bennie 

Kennedy’s (“Pl’s”) “... problem was not with “Prairie State”, but with his (“Pl’s”) employer 

(“Schneider”).” These emails reflected Bennie Kennedy’s attempt to determine why he 

(“Pl”) was being terminated from “Prairie State”. (See Copies of Emails and Copy of 

List/Table of Emails Ordered by Dates/Times for Identification marked as EXHIBIT 

3A and EXHIBIT 3B).

 The date of the sworn declaration of “Hansel” (February 27, 2014), comes 

approximately six (6) months after her (“Hansel’s”) promotion to Interim Vice President 

of Academic Affairs by “Prairie State” (in July 2013). Shortly after “Hansel” gave 

sworn declaration for “Schneider” in 2014, Marie Hansel (“Hansel”) was promoted to 

Vice President of Academic Affairs on or around April 7, 2014. 

3(l). Bennie Kennedy, (“Pl”), developed a considerable reputation as an expert in the 

field of electronics for over thirty (37) years, and writing numerous articles for a large 

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and reputable electronics trade magazine. Also, on numerous occasions (“Pl”) was 

called upon to correct serious electronic problems with machinery at various locations 

including emergency electronic facilities at hospitals. Additionally, Plaintiff, (“Pl”), was 

certified by national boards to teach certification courses for OSHA (Occupational 

Safety and Health Administration). (See Affidavit of Plaintiff marked as EXHIBIT 4).

 The above background and experience of Plaintiff places him (“Pl”) in the 

category of journeyman in electronics. (Journeyman defined is – a trained worker who is 

employed by someone else). Research by this office discovers that there is no such 

animal that can be labeled as “documented journeyman”, however, journeyman can be 

certified based on query as to an individual’s work or background in a specific field – 

Bennie Kennedy, (“Pl”), filled out an employment application for a teaching position at 

“Prairie State” upon which “Prairie State” hired him subsequent to verifying his work 

experience and employment as an electrician which consisted of over thirty (30) years 

at the point of hire in 2004 – JOURNEYMAN. 

3(m). Plaintiff, Bennie Kennedy disclaims any collusiveness in perpetrating a fraud 

upon the students of classes he, (“Pl”), taught as he (“Pl”) believes, and believed, that 

he (“Pl”) had the proper knowledge and experience to teach the classes he (“Pl”) taught 

at “Prairie State”, both credited and non-credited classes, not-with-standing the claims 

alleged by “Hansel” in her (“Hansel’s”) sworn declaration, such that Plaintiff must 

provide such disclaimer to the regional accrediting commission (Higher Learning 

Commission) to protect himself, (“Pl”) , against any future legal actions against “Prairie 

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State” where Plaintiff , Bennie Kennedy maybe added as a defendant by students who 

took credited and non-credited classes taught by Plaintiff, Bennie Kennedy. 

3(n). Plaintiff, Bennie Kennedy finds it necessary to protect his (“Pl’s”) legal interest 

and rights regarding any actions that could precipitate from “Hansel’s” sworn declaration 

that he, Bennie Kennedy, did not have proper credentials or experience or was not a 

“documented journeyman” – there is no such formal title as a “documented 

journeyman”, thus, a copy of this disclaimer in this complaint must be submitted to the 

United Stated Department of Education in Washington D.C. towards any legal action 

they (U. S. Dept. of Education) may deem necessary regarding “Prairie State” collecting 

and receiving federal funds for tuition for the students who took classes taught Bennie 

Kennedy over six (6) years and any class action that may be brought on behalf of said 

students. 

3(o). Plaintiff, Bennie Kennedy also disclaims any funds received as salaries whose 

source was federal student funds under the U. S. Department of Education with any 

knowledge that he, Bennie Kennedy, was not qualified to receive salaries from federal 

funds for classes – which it is alleged - he was not qualified to teach. Said disclaimer 

will necessarily be submitted to the United States Attorney General’s Office for any legal 

actions they (U.S. Attorney General’s Office) may deem necessary to prosecute fraud

regarding receipt of federal funds. 

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3(p). This office, prior to filing a lawsuit against Schneider Electric (“Schneider”) in the 

case cited above, (Case no. 2:12-CV-00122-PRC), wrote in detail to every member of 

the Prairie State College Board, the concern about the termination of Bennie Kennedy 

from teaching at “Prairie State” College. It is the belief of Plaintiff that this “Board” was 

aware that a declaration had been prepared and had been solicited on behalf Schneider 

Electric or Square D and, therefore, said “Board” can be said to have had prior notice 

that a fraudulent document was being drafted and was to be submitted to a federal court 

which represented false statements constituting a criminal act and therefore said 

“Board” can be said to have committed misprision of a felony. Additionally, several 

individuals listed in emails mentioned above can also be said to have had prior 

knowledge that this fraudulent document was to be submitted – also making them 

(individuals listed in emails) criminally liable for misprision of a felony. 

3(q). Plaintiff will identify through additional discovery and investigation, those persons 

who will be identified as DOES. Georgia Karras of Prairie State College headed up the 

section at “Prairie State” under which Bennie Kennedy (“Pl”) taught. Georgia Karras 

was, at all times relevant, Assistant Professor and Coordinator at “Prairie State”. (See 

EXHIBIT 2 Email 09/22/2010 at 10:37AM – This Email reflects that the individual 

under which Bennie Kennedy taught saw no problems with his (“Pl’s”) 

qualifications and credentials). 

3(r). Plaintiff, Bennie Kennedy also indicated in the series of email communications 

mentioned earlier that he (“Pl”) also taught at some period with Lake Land College and 

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Illinois Eastern Community Colleges – both of which are accredited by the same 

accreditation commission as is “Prairie State” according to the Higher Learning 

Commission website. This information was also made known to Dean “Hansel” in the 

course of the exchange of the series of emails mentioned earlier. This, again, reflects 

that Dean “Hansel” was well aware that Bennie Kennedy had the proper and necessary 

background to teach the classes at “Prairie State”. Her (Dean “Hansel’s”) declaration is 

further demonstrated to be a perjured and fraudulent document. 

3(s). As mentioned above, Patty Valenziano sent two (2) emails suggesting that 

Bennie Kennedy (“Pl”) does not have the proper credentials to teach. (See Copy of 

Email Dated 9/21/2010 at 11:30AM To: Georgia Karras and Marie Hansel From: 

Patty Valenziano <pvalenziano@prairiestate.edu> marked as EXHIBIT 2). (See 

Copy of Email Dated 08/11/2010 at 4:30PM By: Patty Valenziano 

<pvalenziano@prairiestate.edu> marked as EXHIBIT 9 attached and made apart 

hereto). (In contrast, see EXHIBIT 2 Email 09/22/2010 at 10:37AM –Email by 

Georgia Karras). (Also see Page 4 of 8 of EXHIBIT 2 Copy of Email Response 

from Georgia Karras). Additionally, “Bennie Kennedy” was offered a teaching 

position in the electronics/electrical field at “Prairie State” on or about May 2011 from 

Edward Jodelka. On or about October 2011, three (3) days before the class was 

scheduled to start, Edward Jodelka indicated that he (Edward Jodelka) had to remove 

“Bennie Kennedy” as the instructor because he (Edward Jodelka) was informed that 

“Bennie Kennedy” had filed a lawsuit against “Prairie State”. Again, “Bennie Kennedy” 

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did not file a lawsuit against either “Schneider” Electric or “Prairie State” and initiated a 

lawsuit against only “Schneider” Electric in February 2012. 

 This constitutes a second breach of contract on the part of “Prairie State”. (See 

Copy of Email Dated 05/12/2011 at 12:06PM To: Bennie Kennedy From: Edward 

Jodelka <EJodelka@prairiestate.edu>, See Copy of Email Dated 10/05/2011 at 

7:46PM From: Bennie Kennedy To: Edward Jodelka <EJodelka@prairiestate.edu>, 

See Copy of Email Dated 10/06/2011 at 10:28AM To: Bennie Kennedy From: 

Edward Jodelka <EJodelka@prairiestate.edu> marked as EXHIBIT 10 attached 

and made apart hereto).

Georgia Karras of “Prairie State” College who headed up the section under which 

“Bennie Kennedy” taught classes at “Prairie State”, sent an email to “Bennie Kennedy” 

outlining the classes she (Georgia Karras) had lined up for “Bennie Kennedy” to teach in 

the Fall of 2010. (See Copy of Email Dated 02/22/2010 at 8:16AM To: Bennie 

Kennedy From: Georgia Karras <gkarras@prairiestate.edu>, Subject: Schedule – 

Fall 2010 marked as EXHIBIT 11 attached and made apart hereto). 

 This scheduled class is an example of the breach of contract which came about 

subsequent to the phone call of July 2010, and this is supported by the fact that 

“Hansel” asked whether they (“Prairie State”) can find someone else to take over the 

Fall 2010 classes that “Bennie Kennedy” was scheduled to teach. (See Copy of Email 

Subject: Re: Bennie Kennedy, Page 3 of 8 and Page 4 of 8, which speak to 

replacing Bennie Kennedy marked as EXHIBIT 2). 

 

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JURISDICTION AND VENUE

 

Jurisdiction is proper in this Court pursuant to 28 U.S.C. §1332(a)(2) because of 

diversity of citizenship established in Case Number: 2:12-cv-00122-PRC that was 

removed to this Court upon motion of the defendants in Case Number: 2:12-cv-00122-

PRC, and that this matter is submitted alleging fraud upon this Court by a declaration 

filed by said defendants in Case Number: 2:12-cv-00122-PRC . Diversity stems from, 

and was established in, Case Number: 2:12-cv-00122-PRC setting forth that Plaintiff, 

Bennie Kennedy who is now a plaintiff in this case, was employed in the state of Indiana 

under the same Case Number: 2:12-cv-00122-PRC . And under Case Number: 2:12-

cv-00122-PRC, defendants were established as citizens of the state of Ohio. 

Finally, (2) the amount in controversy exceeds $75,000 exclusive of 

interest and costs. 

 

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COMMON ALLEGATIONS

1. At all times material hereto, Plaintiff, Bennie Kennedy was harmed by 

defendants in Lake County, Indiana in that Defendant “Hansel” set forth in a sworn 

declaration submitted for the purposes of assisting defendants “Schneider Electric” in 

Case Number: 2:12-cv-00122-PRC that was before This Court on Motion for Summary 

Judgment which was subsequently granted by This Court. 

Said declaration was known by the Declarant, “Hansel” to be false in substance 

and therefore subject to Federal Rules of Civil Procedure 56(h). 

This declaration was clearly known to be false by the board members of “Prairie 

State” and several faculty members of “Prairie State” some of whose names are set 

forth in numerous emails generated between “Bennie Kennedy” and said faculty 

members, e.g. Georgia Karras, Marie Hansel, Vivian Zimmerman, 

rkrauss@prairiestate.edu, Patty Valenziano, lgebhardt@prairiestate.edu. This 

declaration was intended to defeat Plaintiff “Bennie Kennedy” in Case Number: 2:12-cv00122-PRC. (These emails are attached as exhibits to this complaint). 

Said Board of Directors at “Prairie State” and faculty members of “Prairie State” 

will be shown to have had knowledge that the above-mentioned false declaration which 

constitutes fraud on the Court was to be submitted prior to its submission and therefore 

will have committed misprision of a felony in that said fraud can be said to be a 

criminal felony. 

On or about the latter part of the year 2010, this office contacted all Board 

Members of “Prairie State” College inquiring as to the reasons for the termination of 

“Bennie Kennedy’s” teaching assignments. Not one (1) board member of “Prairie State” 

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sought to respond to these inquiries from this (John H. Davis & Associates’) office. This 

fact sets forth knowledge that said board members were aware of the termination of 

“Bennie Kennedy”. It is plaintiff’s (“Bennie Kennedy’s”) belief that said board members 

began determining how best to handle this (termination) situation. Clearly 

demonstrating that the termination was not based on credentials or qualifications to 

teach said classes, particularly after teaching classes for over six (6) years at “Prairie 

State”. (These inquiries to the Board of “Prairie State” by this office, John H. Davis & 

Associates, were based upon work product for the case of “Bennie Kennedy”). 

It is plaintiff’s belief that the board and faculty of “Prairie State” ignored and gave 

no reason to “Bennie Kennedy’s” inquiry or this office’s (John H. Davis & Associates’) 

inquiry on behalf of “Bennie Kennedy” as to his (“Bennie Kennedy’s”) termination 

because said board and faculty of “Prairie State” were concerned that they (“Prairie 

State”) may be made defendants as to liability for said defamation by “Schneider” 

Electric/Square D in that “Prairie State” re-published on numerous occasions the said 

defamation i.e. “using proprietary material” - subjecting “Prairie State” to numerous 

counts of defamation. 

2. At all times material hereto, Defendants, were located and doing business 

in the state of Illinois. 

3. On or about February 27, 2014, Defendant, Marie Hansel (“Hansel”) 

signed a DECLARATION under penalty of perjury as a Dean of Defendant, “Prairie 

State” College, setting forth false statements constituting fraud which was subsequently 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 20 of 51
Page 21 of 51

submitted to this Court by Defendants of Schneider Electric in Case Number: 2:12-cv00122-PRC filed on 03/07/2014. This Court, subsequently, granted a Motion for 

Summary Judgment in Case Number: 2:12-cv-00122-PRC. 

4. “Prairie State” in taking the position that “Bennie Kennedy” was not 

qualified to teach credited and non-credited classes for over six (6) years thereby 

invalidated all the credits granted to students and all the certificates granted to students 

who took classes taught by “Bennie Kennedy”. “Bennie Kennedy” herein sets forth that 

he (“Pl”) was always of the mind that he (“Pl”) was, in fact, qualified to teach said 

classes and cannot be held to have misrepresented to the students who took his (“Pl”) 

classes that their (students’) credits would be, or could be, vacated or negated. Further, 

“Bennie Kennedy” sets forth that he (“Bennie Kennedy”) cannot be shown to be liable to 

said students via any cause of action that might be brought forth on behalf of said 

students and/or the U.S. Department of Education. 

“Bennie Kennedy” also sets forth no responsibility for federal student funds 

received by students who took classes taught by him (“Bennie Kennedy”) at “Prairie 

State” which might be said to have been improperly received based upon any lack of 

qualifications by “Bennie Kennedy” to teach classes to students receiving federal 

student loans. (Therefore this disclaimer by “Bennie Kennedy” will be submitted to the 

U. S. Department of Education and any and all entities dispersing federal student loan 

funds, and the U.S. Attorney General’s Office in Washington D.C.). 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 21 of 51
Page 22 of 51

5. It is the belief of Plaintiff, “Bennie Kennedy” that “Prairie State’s” position, 

which is that he (“Bennie Kennedy”) was terminated because of lack of qualifications to 

teach credited and non-credited classes, creates a liability on all persons at “Prairie 

State” – including the board and faculty at “Prairie State” as well as “Bennie Kennedy” 

for obtaining federal student funds illegally. Therefore “Bennie Kennedy”, again, sets 

forth no intention to receive federal student funds illegally in that “Bennie Kennedy” 

again asserts his (“Bennie Kennedy’s”) proper qualifications to teach classes at “Prairie 

State”. 

6. “Bennie Kennedy” again asserts no responsibility for misleading or 

misrepresenting facts to the regional accreditation commission that there were no 

unqualified faculty teaching classes, particularly credited classes as “Prairie State” when 

the regional accreditation commission did its full accreditation review at “Prairie State” in 

the year 2008/2009 during which period “Bennie Kennedy” was teaching classes at 

“Prairie State” starting from approximately the year 2004 through parts of the year 2010. 

Therefore, “Bennie Kennedy” will submit this disclaimer to said regional accreditation 

commission. 

7. At all times material hereto, “Bennie Kennedy” was a member of their 

(“Prairie State’s”) Adjunct Instructor’s Union (AIU), and as such was entitled to a 

procedural process wherein termination or any disciplinary decisions or actions must 

follow a set process. “Bennie Kennedy” never received the proper contractual agreed 

union process in that “Prairie State” never brought the termination of “Bennie Kennedy” 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 22 of 51
Page 23 of 51

to the union to follow the set contractual proceedings. Therefore, “Prairie State” 

breached the contract and benefits to “Bennie Kennedy” set forth in the union contract 

(AIU) – On two (2) separate occasions, Feb. 2010 and May 2011. 

8. At all times material hereto, “Bennie Kennedy” was not privy to any 

misrepresentations by all named defendants allowing the receipt of federal student 

funds which come from a federally funded program. And, as such, “Bennie Kennedy” is 

hereby acting in the position of a relator regarding any such illegal receipt of federal 

funds by any of the named defendants under the Title 18 U.S.C. 666. 

 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 23 of 51
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CLAIMS

A. PRAIRIE STATE COLLEGE - 

(Also Administrators and Faculty–Individually and Collectively) 

9. Plaintiff restates and pleads paragraphs 1 – 8 above and incorporates the 

same by reference as though fully set forth herein.

COUNT I BREACH OF CONTRACT

10. At all times material hereto, “Bennie Kennedy” was an employee of 

“Prairie State” College as an adjunct faculty and thereby a member of the Adjunct 

Instructors Union (AIU) and had the rights set forth in the contract of AIU with “Prairie 

State” which included a number of procedures required to terminate any adjunct 

instructor. 

Said contract was breached by “Prairie State” in that “Prairie State” failed to 

follow said contractual requirements for termination of “Bennie Kennedy” and thereby 

breached the contractual rights “Bennie Kennedy” had through the AIU contract. Such 

breach harmed “Bennie Kennedy” in that he (“Bennie Kennedy”) lost his (“Bennie 

Kennedy’s”) rights under the contract to defend his (“Bennie Kennedy’s”) continued 

employment as faculty at “Prairie State”. This loss includes salaries and benefits that 

“Bennie Kennedy” had prior to his (“Bennie Kennedy’s”) termination. The amounts of 

said monetary damages are to be determined. This breach occurred, between July 

2010 to the present date, in that, said breach is still unresolved. 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 24 of 51
Page 25 of 51

COUNT II FRAUD

11. At all times material hereto, on or about February 27, 2014 Defendant 

“Hansel” gave a declaration under penalty of perjury setting forth substantive material 

which asserted that “Prairie State” College revoked “Bennie Kennedy’s” approval to 

teach at “Prairie State”. Said declaration was clearly known to be in material substance 

false by the Declarant “Hansel”. 

Said declaration was submitted to the Court in the case of Kennedy vs. 

Schneider Electric Case Number 2:12-cv-122-PRC in their (“Schneider’s”) Motion for 

Summary Judgment which was subsequently granted to Schneider Electric by the 

Court in Case Number 2:12-cv-122-PRC. Subsequent to exhaustive research and 

investigation, facts support that said declaration was false and, indeed, a fraud 

perpetrated upon the Court. (See EXHIBIT 3A and EXHIBIT 3B herein).

Said declaration sets forth in support of allegations that “Bennie Kennedy’s” 

teaching was revoked based on lack of qualifications. 

E.g. The said declaration sets forth such ludicrous and unbelievable statements 

among which the Declarant, “Hansel” states that as Dean at “Prairie State” College, 

“Bennie Kennedy” was not a “documented journeyman”. Further, based on EXHIBIT 

3A and EXHIBIT 3B it is set forth that the decisions to revoke “Bennie Kennedy’s” 

teaching at “Prairie State” comes from these emails which, in part, assert that (1) “...In 

addition they (“Schneider”) indicated that you (“Bennie Kennedy”) did not have the 

minimum number of credential, or certificate to qualify for their (“Schneider’s”) 

requirements to teach”. “These are requirements not of PSC (“Prairie State”) but your 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 25 of 51
Page 26 of 51

(“Bennie Kennedy’s”) employer. You (“Bennie Kennedy”) will need to talk with them 

(“Schneider”) about reinstatement”. 

It is clear from the declarant’s (“Hansel’s”) statements and email communications 

that “Prairie State” was seeking to protect themselves (“Prairie State”) from the possible 

inclusion as a defendant with “Schneider” Electric for defamation against Plaintiff 

“Bennie Kennedy” in the above cited case. Thus, “Prairie State” was motivated to 

assist, albeit with a fraudulent document, “Schneider” Electric in the lawsuit brought 

against “Schneider” Electric by “Bennie Kennedy”. 

The timing of “Prairie State’s” concern about “Bennie Kennedy’s” teaching 

qualifications is clear from all the materials submitted hereto. 

“Schneider” Electric is an electrical machinery corporation and in no fashion an 

academic institution, and certainly not a regional accreditation or “Higher Learning 

Commission”. All of this is to the harm of “Bennie Kennedy.” 

COUNT III MISPRISION OF FELONY

12. At all times material hereto, individuals at “Prairie State” – teachers, 

faculty, administrators, board of directors were aware that a decision was made to 

assist “Schneider” Electric in the lawsuit against them (“Schneider”) by “Bennie 

Kennedy” for purposes of possibly avoiding being named as a co-defendant in the 

“Schneider” Electric case, and therefore, a decision was made to submit a declaration to 

“Schneider” Electric asserting that “Bennie Kennedy” was not terminated because a 

telephone call from “Schneider” Electric. This declaration was known to be false or 

known to contain false information prior to the drafting and submission of said false 

declaration. This false declaration constitutes a fraud upon the Court and having prior 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 26 of 51
Page 27 of 51

knowledge on the intent to draft such a document constituting fraud, represents 

misprision of a felony by all individuals having knowledge that such a document was to 

be submitted. 

COUNT IV RICO/RELATOR

13. At all times material hereto, Defendant, “Prairie State” College – between 

the year 2004 to the year 2010, did enroll students who received federally funded 

student loans in programs directed at “Prairie State” College and said defendants did 

author, by an agent – Dean “Hansel”, faculty at “Prairie State”, a declaration under oath, 

subject to perjury, that a faculty member – namely “Bennie Kennedy” did not have the 

requisite requirements in either certificates, education, or experience such as 

journeyman experience to teach classes to students who were receiving federally 

funded students loans thereby committing fraud upon said program in the U. S. 

Government, violating Title 18 U.S.C. 666 - THEFT OR BRIBERY CONCERNING 

PROGRAMS RECEIVING FEDERAL FUNDS. Thus, Plaintiff, “Bennie Kennedy” is 

acting as relator in the capacity of whistleblower. “Bennie Kennedy” disclaims any 

knowing involvement in this fraud perpetrated by the admission of such perpetration in 

that defendant in said declaration sets forth that “Bennie Kennedy” was not qualified to 

teach, but thus continued from the year 2004 to the year 2010 to continue assigning 

classes for “Bennie Kennedy” to teach. 

As an act of theft of federal funds (Title 18 U.S.C. 666) under RICO (Racketeer 

Influenced and Corrupt Organizations - 18 U.S. Code Chapter 96), the defendant 

received said federal funds individually and collectively, dispersed to each in the form of 

salaries, budgets, benefits, and administrative costs. 

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Page 28 of 51

COUNT V BREACH OF CONTRACT

14. At all times material hereto, “Bennie Kennedy” was an employee of 

“Prairie State” College as an adjunct faculty and thereby a member of the Adjunct 

Instructors Union (AIU) and had the rights set forth in the contract of AIU with “Prairie 

State” which included a number of procedures required to terminate any adjunct 

instructor. 

Said contract was breached by “Prairie State” in that “Prairie State” failed to 

follow said contractual requirements for termination of “Bennie Kennedy” and thereby 

breached the contractual rights “Bennie Kennedy” had through the AIU contract. Such 

breach harmed “Bennie Kennedy” in that he (“Bennie Kennedy”) lost his (“Bennie 

Kennedy’s”) rights under the contract to defend his (“Bennie Kennedy’s”) continued 

employment as faculty at “Prairie State”. This loss includes salaries and benefits that 

“Bennie Kennedy” had prior to his (“Bennie Kennedy’s”) termination. The amounts of 

said monetary damages are to be determined. This breach occurred between October 

2011 to the present date, in that, said breach is still unresolved. 

 WHEREFORE, Plaintiff, “Bennie Kennedy” prays that the Court grants him, 

“Bennie Kennedy” judgment against the Defendant, Prairie State College (“Prairie 

State”) and all of their (“Prairie State’s”) administrators, directors, faculty, and agents in 

damages representing over $75,000.00 and/or to be determined, and that the Court, 

sua sponte refer the criminal portions of the allegations set forth above to federal 

agencies including the United States’ Attorney General’s Office, that this relief 

anticipates compensatory as well as punitive damages, and all other just and proper 

remedies in the premises. 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 28 of 51
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 Respectfully Submitted, 

Dated: April 13, 2016

 /s/ John H. Davis

 John H. Davis, #4812-45 

 Attorney for Plaintiff, Bennie Kennedy 

John H. Davis 

Attorney at Law 

P.O. Box 43 

Crown Point, Indiana 46308-0043 

PHONE: (219) 884-2461 

attyhdavis@gmail.com

B. PRAIRIE STATE COLLEGE 

 BOARD OF DIRECTORS (Individually and Collectively)

15. Plaintiff restates and pleads paragraphs 1 – 14 above and incorporates 

the same by reference as though fully set forth herein. 

COUNT I BREACH OF CONTRACT

16. At all times material hereto, “Bennie Kennedy” was an employee of 

“Prairie State” College as an adjunct faculty and thereby a member of the Adjunct 

Instructors Union (AIU) and had the rights set forth in the contract of AIU with “Prairie 

State” which included a number of procedures required to terminate any adjunct 

instructor. 

Said contract was breached by “Prairie State” in that “Prairie State” failed to 

follow said contractual requirements for termination of “Bennie Kennedy” and thereby 

breached the contractual rights “Bennie Kennedy” had through the AIU contract. Such 

breach harmed “Bennie Kennedy” in that he (“Bennie Kennedy”) lost his (“Bennie 

Kennedy’s”) rights under the contract to defend his (“Bennie Kennedy’s”) continued 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 29 of 51
Page 30 of 51

employment as faculty at “Prairie State”. This loss includes salaries and benefits that 

“Bennie Kennedy” had prior to his (“Bennie Kennedy’s”) termination. The amounts of 

said monetary damages are to be determined. This breach occurred between July 

2010 to the present date, in that, said breach is still unresolved. 

Prairie State College Board of Directors (“Board”) had a fiduciary duty to direct 

the activities of “Prairie State” College and, as such, is responsible for said breach of 

contract. 

COUNT II FRAUD

17. At all times material hereto, on or about February 27, 2014 Defendant 

“Hansel” gave a declaration under penalty of perjury setting forth substantive material 

which asserted that “Prairie State” College revoked “Bennie Kennedy’s” approval to 

teach at “Prairie State”. Said declaration was clearly known to be in material substance 

false by the Declarant “Hansel”. 

Said declaration was submitted to the Court in the case of Kennedy vs. 

Schneider Electric Case Number 2:12-cv-122-PRC in their (“Schneider’s”) Motion for 

Summary Judgment which was subsequently granted to Schneider Electric by the 

Court in Case Number 2:12-cv-122-PRC. Subsequent to exhaustive research and 

investigation, facts support that said declaration was false and, indeed, a fraud 

perpetrated upon the Court. (See EXHIBIT 3A and EXHIBIT 3B herein).

Said declaration sets forth in support of allegations that “Bennie Kennedy’s” 

teaching was revoked based on lack of qualifications. 

E.g. The said declaration sets forth such ludicrous and unbelievable statements 

among which the Declarant, “Hansel” states that as Dean at “Prairie State” College, 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 30 of 51
Page 31 of 51

“Bennie Kennedy” was not a “documented journeyman”. Further, based on EXHIBIT 

3A and EXHIBIT 3B it is set forth that the decisions to revoke “Bennie Kennedy’s” 

teaching at “Prairie State” comes from these emails which, in part, assert that (1) “...In 

addition they (“Schneider”) indicated that you (“Bennie Kennedy”) did not have the 

minimum number of credential, or certificate to qualify for their (“Schneider”) 

requirements to teach”. (2) “These are requirements not of PSC (“Prairie State”) but 

your (“Bennie Kennedy’s”) employer. You (“Bennie Kennedy”) will need to talk with 

them (“Schneider”) about reinstatement”. (“Bennie Kennedy” is still employed at 

“Schneider” Electric). 

There is no such animal as “documented journeyman”. Journeyman is defined 

as an individual who has extensive work experience in a particular esoteric area such 

as electrician/electronics. “Bennie Kennedy” had, at the time of his (“Bennie 

Kennedy’s”) employment at “Prairie State” over thirty-seven (37) years experience in his 

(“Bennie Kennedy’s”) field which was documented via his employment application with 

“Prairie State”. 

The issue has always been whether or not “Bennie Kennedy” was terminated 

based upon a phone call from “Schneider” Electric to “Prairie State’s” Dean “Hansel”. 

It is clear from the declarant’s (“Hansel’s”) statements and email communications 

that “Prairie State” was seeking to protect themselves (“Prairie State”) from the possible 

inclusion as a defendant with “Schneider” Electric for defamation against Plaintiff 

“Bennie Kennedy” in the above cited case. Thus, “Prairie State” was motivated to 

assist, albeit with a fraudulent document, “Schneider” Electric in the lawsuit brought 

against “Schneider” Electric by “Bennie Kennedy”. 

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Page 32 of 51

The timing of “Prairie State’s” concern about “Bennie Kennedy’s” teaching 

qualifications is clear from all the materials submitted hereto. 

“Schneider” Electric is an electrical machinery corporation and in no fashion an 

academic institution, and certainly not a regional accreditation or “Higher Learning 

Commission”. 

Prairie State College Board of Directors (“Board”) were on notice on or about 

August 2010 via letters sent to each board member from this office (John H. Davis & 

Associates) inquiring as to the termination of “Bennie Kennedy’s” employment. This 

“Board” sought to ignore such inquiry and clearly never asserted their (“Board’s”) 

authority and/or exercised their (“Board”) fiduciary duty over members of “Prairie State” 

College administrators and faculty, thus this “Board” is equally liable for said fraud in 

that they (“Board”) had a fiduciary duty to prevent such fraud. All of this is to the harm 

of “Bennie Kennedy.”

COUNT III MISPRISION OF FELONY

18. At all times material hereto, individuals at “Prairie State” – teachers, 

faculty, administrators, board of directors were aware that a decision was made to 

assist “Schneider” Electric in the lawsuit against them (“Schneider”) by “Bennie 

Kennedy” for purposes of possibly avoiding being named as a co-defendant in the 

“Schneider” Electric case, and therefore, a decision was made to submit a declaration to 

“Schneider” Electric asserting that “Bennie Kennedy” was not terminated because a 

telephone call from “Schneider” Electric. This declaration was known to be false or 

known to contain false information prior to the drafting and submission of said false 

declaration. This false declaration constitutes a fraud upon the Court and having prior 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 32 of 51
Page 33 of 51

knowledge on the intent to draft such a document constituting fraud, represents 

misprision of a felony by all individuals having knowledge that such a document was to 

be submitted. 

“Prairie State” Board of Directors (“Board”), having had prior knowledge to the 

decision to assist “Schneider” Electric by drafting and submitting a sworn declaration as 

to alleged reasons that “Bennie Kennedy’s” teaching classes at “Prairie State” was 

being revoked, thus the “Board” is responsible for said declaration which is a fraud and 

therefore said “Board” is liable for commission of misprision of a felony.

 

COUNT IV RICO/RELATOR

19. At all times material hereto, Defendant, “Prairie State” College – between 

the year 2004 to the year 2010, did enroll students who received federally funded 

student loans in programs directed at “Prairie State” College and said defendants did 

author, by an agent – Dean “Hansel”, faculty at “Prairie State”, a declaration under oath, 

subject to perjury, that a faculty member – namely “Bennie Kennedy” did not have the 

requisite requirements in either certificates, education, or experience such as 

journeyman experience to teach classes to students who were receiving federally 

funded students loans thereby committing fraud upon said program in the U. S. 

Government, violating Title 18 U.S.C. 666 - THEFT OR BRIBERY CONCERNING 

PROGRAMS RECEIVING FEDERAL FUNDS. Thus, Plaintiff, “Bennie Kennedy” is 

acting as relator in the capacity of whistleblower. “Bennie Kennedy” disclaims any 

knowing involvement in this fraud perpetrated by the admission of such perpetration in 

that defendant in said declaration sets forth that “Bennie Kennedy” was not qualified to 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 33 of 51
Page 34 of 51

teach, but thus continued from the year 2004 to the year 2010 to continue assigning 

classes for “Bennie Kennedy” to teach. 

As an act of theft of federal funds (Title 18 U.S.C. 666) under RICO (Racketeer 

Influenced and Corrupt Organizations - 18 U.S. Code Chapter 96), the defendant 

received said federal funds individually and collectively, dispersed to each in the form of 

salaries, budgets, benefits, and administrative costs. 

The Prairie State College Board of Directors (“Board”) as a defendant in this 

matter had a fiduciary duty to prevent the above-cited actions by “Prairie State” College 

administrators and faculty. 

COUNT V BREACH OF CONTRACT

20. At all times material hereto, “Bennie Kennedy” was an employee of 

“Prairie State” College as an adjunct faculty and thereby a member of the Adjunct 

Instructors Union (AIU) and had the rights set forth in the contract of AIU with “Prairie 

State” which included a number of procedures required to terminate any adjunct 

instructor. 

Said contract was breached by “Prairie State” in that “Prairie State” failed to 

follow said contractual requirements for termination of “Bennie Kennedy” and thereby 

breached the contractual rights “Bennie Kennedy” had through the AIU contract. Such 

breach harmed “Bennie Kennedy” in that he (“Bennie Kennedy”) lost his (“Bennie 

Kennedy’s”) rights under the contract to defend his (“Bennie Kennedy’s”) continued 

employment as faculty at “Prairie State”. This loss includes salaries and benefits that 

“Bennie Kennedy” had prior to his (“Bennie Kennedy’s”) termination. The amounts of 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 34 of 51
Page 35 of 51

said monetary damages are to be determined. This breach occurred between October 

2011 to the present date, in that, said breach is still unresolved. 

 WHEREFORE, Plaintiff, “Bennie Kennedy” prays that the Court grants him, 

“Bennie Kennedy” judgment against the Defendant, Prairie State College Board of 

Directors (“Board” ) and agents in damages representing over $75,000.00 and/or to be 

determined, and that the Court, sua sponte refer the criminal portions of the allegations 

set forth above to federal agencies including the United States’ Attorney General’s 

Office, that this relief anticipates compensatory as well as punitive damages, and all 

other just and proper remedies in the premises. 

 Respectfully Submitted, 

Dated: April 13, 2016

 /s/ John H. Davis

 John H. Davis, #4812-45 

 Attorney for Plaintiff, Bennie Kennedy 

John H. Davis 

Attorney at Law 

P.O. Box 43 

Crown Point, Indiana 46308-0043 

PHONE: (219) 884-2461 

attyhdavis@gmail.com

C. MARIE HANSEL (Individually and Collectively)

21. Plaintiff restates and pleads paragraphs 1 – 20 above and incorporates

the same by reference as though fully set forth herein. 

COUNT I BREACH OF CONTRACT

22. At all times material hereto, “Bennie Kennedy” was an employee of 

“Prairie State” College as an adjunct faculty and thereby a member of the Adjunct 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 35 of 51
Page 36 of 51

Instructors Union (AIU) and had the rights set forth in the contract of AIU with “Prairie 

State” which included a number of procedures required to terminate any adjunct 

instructor. 

Said contract was breached by “Prairie State” in that “Prairie State” failed to 

follow said contractual requirements for termination of “Bennie Kennedy” and thereby 

breached the contractual rights “Bennie Kennedy” had through the AIU contract. Such 

breach harmed “Bennie Kennedy” in that he (“Bennie Kennedy”) lost his (“Bennie 

Kennedy’s”) rights under the contract to defend his (“Bennie Kennedy’s”) continued 

employment as faculty at “Prairie State”. This loss includes salaries and benefits that 

“Bennie Kennedy” had prior to his (“Bennie Kennedy’s”) termination. The amounts of 

said monetary damages are to be determined. This breach occurred between July 

2010 to the present date, in that, said breach is still unresolved. 

Defendant, “Hansel” – by her (“Hansel’s”) actions, refused and failed to comply 

with the procedural requirements of AIU in the termination of “Bennie Kennedy’s” 

teaching and intentionally subverted his (“Bennie Kennedy’s”) contractual rights under 

the union contract. “Hansel” as Dean was, and should have been, fully familiar with the 

procedures for termination or revoking teaching by adjunct faculty at “Prairie State” in 

her (“Hansel’s”) administrative capacity, she (“Hansel”) can be said to have acted in a 

way that was egregious in the harm to “Bennie Kennedy” and intentional, thus requiring 

punitive as well as compensatory damages. 

COUNT II FRAUD

23. At all times material hereto, on or about February 27, 2014 Defendant 

“Hansel” gave a declaration under penalty of perjury setting forth substantive material 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 36 of 51
Page 37 of 51

which asserted that “Prairie State” College revoked “Bennie Kennedy’s” approval to 

teach at “Prairie State”. Said declaration was clearly known to be in material substance 

false by the Declarant “Hansel”. 

Said declaration was submitted to the Court in the case of Kennedy vs. 

Schneider Electric Case Number 2:12-cv-122-PRC in their (“Schneider’s”) Motion for 

Summary Judgment which was subsequently granted to Schneider Electric by the 

Court in Case Number 2:12-cv-122-PRC. Subsequent to exhaustive research and 

investigation, facts support that said declaration was false and, indeed, a fraud 

perpetrated upon the Court. (See EXHIBIT 2, EXHIBIT 3A, EXHIBIT 3B and EXHIBIT 

7 herein).

Said declaration sets forth in support of allegations that “Bennie Kennedy’s” 

teaching was revoked based on lack of qualifications. 

E.g. The said declaration sets forth such ludicrous and unbelievable statements 

among which the Declarant, “Hansel” states that as Dean at “Prairie State” College, 

“Bennie Kennedy” was not a “documented journeyman”. Further, based on EXHIBIT 2, 

EXHIBIT 3A and EXHIBIT 3B - it is set forth that the decisions to revoke “Bennie 

Kennedy’s” teaching at “Prairie State” comes from these emails which, in part, assert 

that (1) “...In addition they (“Schneider”) indicated that you (“Bennie Kennedy”) did not 

have the minimum number of credential, or certificate to qualify for their (“Schneider”) 

requirements to teach”. (2) “These are requirements not of PSC (“Prairie State”) but 

your (“Bennie Kennedy’s”) employer. You (“Bennie Kennedy”) will need to talk with 

them (“Schneider”) about reinstatement”. (“Bennie Kennedy” is still employed at 

“Schneider” Electric). 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 37 of 51
Page 38 of 51

There is no such animal as “documented journeyman”. Journeyman is defined 

as an individual who has extensive work experience in a particular esoteric area such 

as electrician/electronics. “Bennie Kennedy” had, at the time of his (“Bennie 

Kennedy’s”) employment at “Prairie State” over thirty-seven (37) years experience in his 

(“Bennie Kennedy’s”) field which was documented via his employment application with 

“Prairie State”. 

The issue has always been whether or not “Bennie Kennedy” was terminated 

based upon a phone call from “Schneider” Electric to “Prairie State’s” Dean “Hansel”. 

It is clear from the declarant’s (“Hansel’s”) statements and email communications 

that “Prairie State” was seeking to protect themselves (“Prairie State”) from the possible 

inclusion as a defendant with “Schneider” Electric for defamation against Plaintiff 

“Bennie Kennedy” in the above cited case. Thus, “Prairie State” was motivated to 

assist, albeit with a fraudulent document, “Schneider” Electric in the lawsuit brought 

against “Schneider” Electric by “Bennie Kennedy”. 

The timing of “Prairie State’s” concern about “Bennie Kennedy’s” teaching 

qualifications is clear from all the materials submitted hereto. 

“Schneider” Electric is an electrical machinery corporation and in no fashion an 

academic institution, and certainly not a regional accreditation or “Higher Learning 

Commission”. 

Defendant “Hansel” in her sworn declaration states that Olson, of Schneider 

Electric/Square D in her (Olson’s) telephone call to “Hansel”, never stated to “Hansel” 

that “Bennie Kennedy” used proprietary information..., however, Dean “Hansel’s” own 

fellow “Prairie State” employee, Zimmerman states in an email that “Hansel” stated that 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 38 of 51
Page 39 of 51

she (“Hansel”) was told in said telephone communication with “Schneider” Electric that 

“Bennie Kennedy” used proprietary information. (See EXHIBIT 3B - List/Table of 

Emails Ordered by Date/Time #15 and #8 Dated 01/20/2011 at 12:10PM). (Also see 

Copy of Email from Georgia Karras Dated 09/22/2010 @10:37AM Page 3 of 8 

marked as EXHIBIT 2).

The declarant, Dean “Hansel” has clearly committed a fraud upon the Court in 

her (“Hansel’s”) sworn declaration. 

COUNT III MISPRISION OF FELONY

24. At all times material hereto, individuals at “Prairie State” – teachers, 

faculty, administrators, board of directors were aware that a decision was made to 

assist “Schneider” Electric in the lawsuit against them (“Schneider”) by “Bennie 

Kennedy” for purposes of possibly avoiding being named as a co-defendant in the 

“Schneider” Electric case, and therefore, a decision was made to submit a declaration to 

“Schneider” Electric asserting that “Bennie Kennedy” was not terminated because of a 

telephone call from “Schneider” Electric. This declaration was known to be false or 

known to contain false information prior to the drafting and submission of said false 

declaration. This false declaration constitutes a fraud upon the Court and having prior 

knowledge on the intent to draft such a document constituting fraud, represents 

misprision of a felony by all individuals having knowledge that such a document was to 

be submitted. 

Dean “Hansel” was the sworn declarant.

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COUNT IV RICO/RELATOR

25. At all times material hereto, Defendant, “Prairie State” College – between 

the year 2004 to the year 2010, did enroll students who received federally funded 

student loans in programs directed at “Prairie State” College and said defendants did 

author, by an agent – Dean “Hansel”, faculty at “Prairie State”, a declaration under oath, 

subject to perjury, that a faculty member – namely “Bennie Kennedy” did not have the 

requisite requirements in either certificates, education, or experience such as 

journeyman experience to teach classes to students who were receiving federally 

funded student loans thereby committing fraud upon said program in the U. S. 

Government, violating Title 18 U.S.C. 666 - THEFT OR BRIBERY CONCERNING 

PROGRAMS RECEIVING FEDERAL FUNDS. Thus, Plaintiff, “Bennie Kennedy” is 

acting as relator in the capacity of whistleblower. “Bennie Kennedy” disclaims any 

knowing involvement in this fraud perpetrated by the admission of such perpetration in 

that defendant in said declaration sets forth that “Bennie Kennedy” was not qualified to 

teach, but thus continued from the year 2004 to the year 2010 to continue assigning 

classes for “Bennie Kennedy” to teach. 

As an act of theft of federal funds (Title 18 U.S.C. 666) under RICO (Racketeer 

Influenced and Corrupt Organizations - 18 U.S. Code Chapter 96), the defendant 

received said federal funds individually and collectively, dispersed to each in the form of 

salaries, budgets, benefits, and administrative costs. 

COUNT V BREACH OF CONTRACT

26. At all times material hereto, “Bennie Kennedy” was an employee of 

“Prairie State” College as an adjunct faculty and thereby a member of the Adjunct 

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Page 41 of 51

Instructors Union (AIU) and had the rights set forth in the contract of AIU with “Prairie 

State” which included a number of procedures required to terminate any adjunct 

instructor. 

Said contract was breached by “Prairie State” in that “Prairie State” failed to 

follow said contractual requirements for termination of “Bennie Kennedy” and thereby 

breached the contractual rights “Bennie Kennedy” had through the AIU contract. Such 

breach harmed “Bennie Kennedy” in that he (“Bennie Kennedy”) lost his (“Bennie 

Kennedy’s”) rights under the contract to defend his (“Bennie Kennedy’s”) continued 

employment as faculty at “Prairie State”. This loss includes salaries and benefits that 

“Bennie Kennedy” had prior to his (“Bennie Kennedy’s”) termination. The amounts of 

said monetary damages are to be determined. This breach occurred between October 

2011 to the present date, in that, said breach is still unresolved. 

 WHEREFORE, Plaintiff, “Bennie Kennedy” prays that the Court grants him, 

“Bennie Kennedy”, judgment against the Defendant, Marie Hansel (“Hansel”) 

individually and as an agent of Prairie State College (“Prairie State”) for damages 

representing over $75,000.00 and/or to be determined, and that the Court, sua sponte

refer the criminal portions of the allegations set forth above to federal agencies including 

the United States’ Attorney General’s Office, that this relief anticipates compensatory as 

well as punitive damages, and all other just and proper remedies in the premises. 

 

 Respectfully Submitted, 

Dated: April 13, 2016

 /s/ John H. Davis

 John H. Davis, #4812-45 

 Attorney for Plaintiff, Bennie Kennedy 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 41 of 51
Page 42 of 51

John H. Davis 

Attorney at Law 

P.O. Box 43 

Crown Point, Indiana 46308-0043 

PHONE: (219) 884-2461 

attyhdavis@gmail.com

 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 42 of 51
Page 43 of 51

D. PATTY VALENZIANO (Individually and Collectively) 

27. Plaintiff restates and pleads paragraphs 1 – 26 above and incorporates 

the same by reference as though fully set forth herein. 

COUNT I BREACH OF CONTRACT

28. At all times material hereto, “Bennie Kennedy” was an employee of 

“Prairie State” College as an adjunct faculty and thereby a member of the Adjunct 

Instructors Union (AIU) and had the rights set forth in the contract of AIU with “Prairie 

State” which included a number of procedures required to terminate any adjunct 

instructor. 

Said contract was breached by “Prairie State” in that “Prairie State” failed to 

follow said contractual requirements for termination of “Bennie Kennedy” and thereby 

breached the contractual rights “Bennie Kennedy” had through the AIU contract. Such 

breach harmed “Bennie Kennedy” in that he (“Bennie Kennedy”) lost his (“Bennie 

Kennedy’s”) rights under the contract to defend his (“Bennie Kennedy’s”) continued 

employment as faculty at “Prairie State”. This loss includes salaries and benefits that 

“Bennie Kennedy” had prior to his (“Bennie Kennedy’s”) termination. The amounts of 

said monetary damages are to be determined. This breach occurred between July 

2010 to the present date, in that, said breach is still unresolved. 

Defendant, “Valenziano” – by her (“Valenziano”) actions, refused and failed to 

comply with the procedural requirements of AIU in the termination of “Bennie 

Kennedy’s” teaching and intentionally subverted his (“Bennie Kennedy’s”) contractual 

rights under the union contract. “Valenziano” as Associate Dean was, and should have 

been, fully familiar with the procedures for termination or revoking teaching by adjunct 

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Page 44 of 51

faculty at “Prairie State” in her (“Valenziano’s”) administrative capacity, she 

(“Valenziano”) can be said to have acted in a way that was egregious in the harm to 

“Bennie Kennedy” and intentional, thus requiring punitive as well as compensatory 

damages. 

COUNT II FRAUD

29. At all times material hereto, on or about February 27, 2014 Defendant 

“Hansel” gave a declaration under penalty of perjury setting forth substantive material 

which asserted that “Prairie State” College revoked “Bennie Kennedy’s” approval to 

teach at “Prairie State”. Said declaration was clearly known to be in material substance 

false by the Declarant “Hansel”. 

 Said declaration was submitted to the Court in the case of Kennedy vs. 

Schneider Electric Case Number 2:12-cv-122-PRC in their (“Schneider’s”) Motion for 

Summary Judgment which was subsequently granted to Schneider Electric by the 

Court in Case Number 2:12-cv-122-PRC. Subsequent to exhaustive research and 

investigation, facts support that said declaration was false and, indeed, a fraud 

perpetrated upon the Court. Patty “Valenziano” actively participated and personally 

assisted Marie “Hansel” in perpetrating the perjured declaration. (See EXHIBIT 3A and 

EXHIBIT 3B herein). (See Copy of Email Dated 09/21/2010 at 11:30AM To: Georgia 

Karras, Marie Hansel From: Patty Valenziano <pvalenziano@prairiestate.edu>, 

Subject: Re: Bennie Kennedy Pages 1 to 8 which speaks to replacing Bennie 

Kennedy marked as EXHIBIT 2 herein). 

Said declaration sets forth in support of allegations that “Bennie Kennedy’s” 

teaching was revoked based on lack of qualifications. 

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E.g. The said declaration sets forth such ludicrous and unbelievable statements 

among which the Declarant, “Hansel” states that as Dean at “Prairie State” College, 

“Bennie Kennedy” was not a “documented journeyman”. Further, based on EXHIBIT 

3A and EXHIBIT 3B it is set forth that the decisions to revoke “Bennie Kennedy’s” 

teaching at “Prairie State” comes from these emails which, in part, assert that (1) “...In 

addition they (“Schneider”) indicated that you (“Bennie Kennedy”) did not have the 

minimum number of credential, or certificate to qualify for their (“Schneider”) 

requirements to teach”. (2) “These are requirements not of PSC (“Prairie State”) but 

your (“Bennie Kennedy’s”) employer. You (“Bennie Kennedy”) will need to talk with 

them (“Schneider”) about reinstatement”. (“Bennie Kennedy” is still employed at 

“Schneider” Electric). 

There is no such animal as “documented journeyman”. Journeyman is defined 

as an individual who has extensive work experience in a particular esoteric area such 

as electrician/electronics. “Bennie Kennedy” had, at the time of his (“Bennie 

Kennedy’s”) employment at “Prairie State” over thirty-seven (37) years experience in his 

(“Bennie Kennedy’s”) field which was documented via his employment application with 

“Prairie State”. 

The issue has always been whether or not “Bennie Kennedy” was terminated 

based upon a phone call from “Schneider” Electric to “Prairie State’s” Dean “Hansel”. 

It is clear from the declarant’s (“Hansel’s”) statements and email communications 

that “Prairie State” was seeking to protect themselves (“Prairie State”) from the possible 

inclusion as a defendant with “Schneider” Electric for defamation against Plaintiff 

“Bennie Kennedy” in the above cited case. Thus, “Prairie State” was motivated to 

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Page 46 of 51

assist, albeit with a fraudulent document, “Schneider” Electric in the lawsuit brought 

against “Schneider” Electric by “Bennie Kennedy”. 

The timing of “Prairie State’s” concern about “Bennie Kennedy’s” teaching 

qualifications is clear from all the materials submitted hereto. 

“Schneider” Electric is an electrical machinery corporation and in no fashion an 

academic institution, and certainly not a regional accreditation or “Higher Learning 

Commission”. 

Defendant “Hansel” in her sworn declaration states that Olson, of Schneider 

Electric/Square D in her (Olson’s) telephone call to “Hansel”, never stated to “Hansel” 

that “Bennie Kennedy” used proprietary information...,however, Dean “Hansel’s” own 

fellow “Prairie State” employee, Zimmerman states in an email that “Hansel” stated that 

she (“Hansel”) was told in said telephone communication with “Schneider” Electric that 

“Bennie Kennedy” used proprietary information. (See EXHIBIT 3B Email #15 and #8 

Dated 01/20/2011 at 12:10PM).

The declarant, Dean “Hansel” has clearly committed a fraud upon the Court in 

her (“Hansel’s”) sworn declaration. 

COUNT III MISPRISION OF FELONY

30. At all times material hereto, individuals at “Prairie State” – teachers, 

faculty, administrators, board of directors were aware that a decision was made to 

assist “Schneider” Electric in the lawsuit against them (“Schneider”) by “Bennie 

Kennedy” for purposes of possibly avoiding being named as a co-defendant in the 

“Schneider” Electric case, and therefore, a decision was made to submit a declaration to 

“Schneider” Electric asserting that “Bennie Kennedy” was not terminated because of a 

USDC IN/ND case 2:16-cv-00125-JVB-JEM document 1 filed 04/14/16 page 46 of 51
Page 47 of 51

telephone call from “Schneider” Electric. This declaration was known to be false or 

known to contain false information prior to the drafting and submission of said false 

declaration. This false declaration constitutes a fraud upon the Court and having prior 

knowledge on the intent to draft such a document constituting fraud, represents 

misprision of a felony by all individuals having knowledge that such a document was to 

be submitted. 

Dean “Hansel” was the sworn declarant. 

COUNT IV RICO/RELATOR

31. At all times material hereto, Defendant, “Prairie State” College – between 

the year 2004 to the year 2010, did enroll students who received federally funded 

student loans in programs directed at “Prairie State” College and said defendants did 

author, by an agent – Dean “Hansel”, faculty at “Prairie State”, a declaration under oath, 

subject to perjury, that a faculty member – namely “Bennie Kennedy” did not have the 

requisite requirements in either certificates, education, or experience such as 

journeyman experience to teach classes to students who were receiving federally

funded student loans thereby committing fraud upon said program in the U. S. 

Government, violating Title 18 U.S.C. 666 - THEFT OR BRIBERY CONCERNING 

PROGRAMS RECEIVING FEDERAL FUNDS. Thus, Plaintiff, “Bennie Kennedy” is 

acting as relator in the capacity of whistleblower. “Bennie Kennedy” disclaims any 

knowing involvement in this fraud perpetrated by the admission of such perpetration in 

that defendant in said declaration sets forth that “Bennie Kennedy” was not qualified to 

teach, but thus continued from the year 2004 to the year 2010 to continue assigning 

classes for “Bennie Kennedy” to teach. 

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Page 48 of 51

As an act of theft of federal funds (Title 18 U.S.C. 666) under RICO (Racketeer 

Influenced and Corrupt Organizations - 18 U.S. Code Chapter 96), the defendant 

received said federal funds individually and collectively, dispersed to each in the form of 

salaries, budgets, benefits, and administrative costs. 

COUNT V BREACH OF CONTRACT

32. At all times material hereto, “Bennie Kennedy” was an employee of 

“Prairie State” College as an adjunct faculty and thereby a member of the Adjunct 

Instructors Union (AIU) and had the rights set forth in the contract of AIU with “Prairie 

State” which included a number of procedures required to terminate any adjunct 

instructor. 

Said contract was breached by “Prairie State” in that “Prairie State” failed to 

follow said contractual requirements for termination of “Bennie Kennedy” and thereby 

breached the contractual rights “Bennie Kennedy” had through the AIU contract. Such 

breach harmed “Bennie Kennedy” in that he (“Bennie Kennedy”) lost his (“Bennie 

Kennedy’s”) rights under the contract to defend his (“Bennie Kennedy’s”) continued 

employment as faculty at “Prairie State”. This loss includes salaries and benefits that 

“Bennie Kennedy” had prior to his (“Bennie Kennedy’s”) termination. The amounts of 

said monetary damages are to be determined. This breach occurred between October 

2011 to the present date in that said breach is still unresolved. 

 WHEREFORE, Plaintiff, “Bennie Kennedy” prays that the Court grants him, 

“Bennie Kennedy” judgment against the Defendant, Patty Valenziano (“Valenziano”) 

individually and as an agent of Prairie State College (“Prairie State”) for damages 

representing over $75,000.00 and/or to be determined, and that the Court, sua sponte

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refer the criminal portions of the allegations set forth above to federal agencies including 

the United States’ Attorney General’s Office, that this relief anticipates compensatory as 

well as punitive damages, and all other just and proper remedies in the premises. 

 

 Respectfully Submitted, 

Dated: April 13, 2016

 /s/ John H. Davis

 John H. Davis, #4812-45 

 Attorney for Plaintiff, Bennie Kennedy 

John H. Davis 

Attorney at Law 

P.O. Box 43 

Crown Point, Indiana 46308-0043 

PHONE: (219) 884-2461 

attyhdavis@gmail.com

 

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JURY DEMAND 

Plaintiff demands trial by Jury. 

 

Dated: April 13, 2016 /s/ John H. Davis

 John H. Davis, #4812-45 

 Attorney for Plaintiff, Bennie Kennedy 

John H. Davis 

Attorney at Law 

P.O. Box 43 

Crown Point, Indiana 46308-0043 

PHONE: (219) 884-2461 

attyhdavis@gmail.com

 

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INDEX

EXHIBIT 1 

EXHIBIT 2 

EXHIBIT 3A 

EXHIBIT 3B 

EXHIBIT 4 

EXHIBIT 5 

EXHIBIT 6 

EXHIBIT 7 

EXHIBIT 8 

EXHIBIT 9 

EXHIBIT 10 

EXHIBIT 11 

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