The Worst Counselor in the World?

JERSEY CITY, N.J. (CN) - A woman says the director of outpatient treatment at an addiction clinic abused his position to have sex with her, without telling her he is married, HIV-positive and has hepatitis C.

D.V. sued Cura and Reinaldo Velez in Hudson County Court.

She says she was an inpatient at Cura's Secaucus facility in 2007 and an outpatient at its Newark outlet. She says that after she became an outpatient, "Velez improperly used his position as director of out patient treatment to initiate an intimate relationship with plaintiff. In so doing, defendant Velez violated the ethical and professional norms of relevant and controlling all addiction counselors."

She claims Velez's "controlling and outrageous and flagrant wrongdoing" was so blatant that it "was known to all or should have been known to all."

The 13-count complaint includes wrongful firing. D.V. says she began work as a volunteer for Cura sometime after she became an outpatient, but the complaint does not make clear just when this happened, nor if or when she became a paid employee.

D.V. she says Velez prohibited her from eating lunch with "with any other worker in the facility" but him; prohibited her from communicating with "all coworkers, colleagues and clients" at Cura during work or after hours; restricted her freedom of movement and "insisted on picking her up and dropping her off wherever she went."

She adds: "Whenever plaintiff was serving a male client, defendant Velez would become intrusive and interfere, conduct that demeaned plaintiff and prevented clients from receiving services.

"Indeed, defendant Velez as a manager of out patient treatment manipulated the assignment of patients so that males were removed from plaintiff's case list - even after therapeutic relationships had been established."

Then, she says, Velez had her transferred to Cura's "New Hope facility in Irvington," where she had to work directly under him. She says that at Newark and in Irvington, "Velez often erupted into rages of jealousy" and "threatened her with violence."

She claims: "Defendant Velez told plaintiff that if his wife leaves him because of discovering that he was cheating with her, that 'he would F K her up or get someone else to F k her up.'

"b. Defendant Velez once threatened to slice plaintiff's face.

"c. Defendant Velez would subject plaintiff to constant demeaning treatment and verbal assaults."

She says: "Defendant Velez had a therapeutic and professional relationship with plaintiff before, during, and after the intimate relationship.

"Defendant Velez never disclosed to plaintiff that he was HIV positive nor that he was hepatitis C positive.

"Defendant Velez repeatedly and insistently sought to have unprotected sexual intercourse and oral sex with plaintiff.

"Defendant Velez also represented that he was single to plaintiff and promised her marriage.

"Defendant Velez also promised plaintiff that she would be hired by CURA as a counselor and in furtherance to this had plaintiff hired as a volunteer with the goal being to transition to a paid employee.

"More specifically, defendant Velez promised 'to sign off on plaintiff's CADC package,' that is to get plaintiff into a program to become a Certified Alcohol and Drug Counselor."

She says she did not find out that Velez had hepatitis C and was HIV positive until a co-worker told her in December 2010. She adds that "it was common knowledge and indeed a matter of record that Velez was HIV positive."

And she says that "Cura had ignored numerous complaints about defendant Velez over the years."

She says that "Velez has continued to harass and stalk plaintiff seeking to entice her back into an intimate relationship despite her clear and adamant demand that Velez leave her alone," and that she had to take out a restraining order against him in July 2010, and still lives in fear of contracting AIDS or hepatitis C and "of being assaulted by defendant or his agents."

She seeks punitive damages for reckless exposure to HIV, hostile work environment, quid pro quo sexual harassment, discrimination, wrongful firing, intentional infliction of emotional distress, stalking and harassment, and assault and battery.

She is represented by Daniel Sexton.

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