DYFS Tort Notices 2015

2700 PACIFIC AvENUE
WILDWOOD, NEW jERSEY o!h6o
609
729
I333
FAX 609 522 4927

WWW.CAl'ELEGALCOM
ATTORNEYS AT LAW
STEPHEN
W.
BARR*
L. CoRRADO
JoSEPH C. GRASSl
FRANK
SUZANNF. PASLEY
CHRISTOPHER GrLUN-SCHWARTZ*
December 29, 2014
CERTIFIED
CiVIL TRJALAITOI!NEY
"CERTIFIED CRIMINAl TRIAl AlTORNEY
VIA CERTIFIED MAIL #7011 2970 0000 1776 8367

Division of Child and Protection Permanency
Department of Children and Families
State of New Jersey
P.O. Box 717
Trenton, NJ 08625
t ADMITTED TO PRACTICE IN PENNSYLVANIA AND
. NEW jERSEY
NOTICE OF TORT CLAIM

This is notice to you (NJSA 59:1-1} ofthe assertion of a claim against you
and the following information is submitted (pursuant to NJSA 59:1-4}:
A.
Claimant:
Josephine Raimondo on behalf of minors C.R., N.R., and
J.R.
B.
Notices:
All notices with respect to this claim are to be sent to
Joseph C. Grassi, Esquire at Barry, Corrado & Grassi, P.C., 2700 Pacific Avenue,
Wildwood, New Jersey, 08260.
C.
Date, place and other circumstances of occurrence or transaction:
On November 19, 2008 C.R., N.R., and J.R. were removed from their family home.
The Division of Child and Protection Permanency, Department of Children and
Families, State of New Jersey placed the three children in foster care of Shelley
and Richard Tozer. The Division, including their managers, supervisors, and
employees, failed to screen, train, and/or supervise the Tozers and the children
during their term in foster care. C.R., N.R., and J.R. were left under the care of
teenage children and subjected to physical and emotional abuse.
D.
General description of injuries, damages or losses known at present
time: Physical, mental, and emotional damages.
E.
Name(s) of public entity employee(s) causing the injuries, damages or
losses: Division of Child and Protection Permanency, Department of Children and
Families, State of New Jersey; Unknown Employees and/or Supervisors
F.
Amount presently claimed:

Unknown at present.
G.
Estimated amount of prospective injuries, damages or losses:

Unknown at present
H.
Basis of computation of amount claimed:

Damages are unliquidated.
BARRY, CORRADO & GRASSl, P.C.
~
-----
~.,.By~:__~
Joseph C. Grassi, Esquire
Attorney for Claimant
_,./
Dated: December 29, 2014

cc:
Client
Tort and Contract Unit
Department of Treasury
Bureau of Risk Management
P.O. Box 620
Trenton, NJ 08625
VIA CERTIFIED MAIL #7011 2970 0000 1776 8374
Law Offices
Stathis & Leonardis

32 South Main Street
Edison, New Jersey 08837
Gregory A. Stathis
Phone: (732) 494-0600

Fax:
(732) 494-0206
Member of NJ Bar
Nicholas J. Leonardis
Member ofNJ & NY Bar
Certified by the Supreme Court of
New Jersey as a Civil Trial Allorney
File No: 14-3180NJL
Micltae/ D. Drivas
MemberofNJ & NY Bar
February 19, 2015
Sent via regular mail and cmjrrr

State of New Jersey
20 West State Street, 4th Floor
P.O. Box 729
Trenton NJ 08625-0729
Divison of Child Protection & Permanency

f/k/a Divison of Youth & Farniiy Services
50 East State Street
PO Box 717
Tort Claims Unit

State of New Jersey
Department of the Treasury
Division of Risk Management
20 West State Street, 6th floor
P.O. Box620
Trenton NJ 08625
Tort Claims Unit

New Jersey Dept of Law & Public Safety
Office of the Attorney General
.
PO Box 112
Re:
Ladies & Gentlemen:

This office represents the above-referenced Claimant.
Served upon you is Notice of Tort Claim.
/ ./
NiCI'iolas J. Leonardis
_,,!'
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NJL/Ijb
Encl.
(/
NOTICE OF CLAIM PURSUANT TO TITLE 59

CLAIMS AGAINST PUBLIC ENTITIES
Pursuant to N.J.S.A.59: 8-4, the within claim is presented:

TO:
Via Certified Mail, Return Receipt Requested and

Via Regular United States Mail
State of New Jersey

20 West State Street, 4th Floor
P.O. Box 729
Trenton, New Jersey 08625-0729
Division of Child Protection and Permanency formerly known as
Division of Youth and Family Services
50 East State Street
P.O. Box 717
Trenton, N.J. 08625-0717
Employees of the Division including but not limited to
Christopher Duggan and his supervisors
State of New Jersey
Department of the Treasury
Division of Risk Management
20 West State Street, 6th floor
P.O. Box 620
Trenton, N.J. 08625
Attn: Tort Claim Unit
New Jersey Department of Law and Public Safety
Office of the Attorney General of the State of New Jersey
P.O. Box 112
Attn: Tort Claims
A.
NAME AND ADDRESS OF CLAIMANT

M
A
asserts this claim for personal injuries against the
public entities set forth above. M
A 's residential address
is 4 Kohls Street, Monmouth Junction, New Jersey 08852.
B.
The post office address to which the person presenting the

claim desires notice to be sent is:
Nicholas J. Leonardis, Esq.
Stathis & Leonardis
32 South Main Street
Edison, New Jersey 08837
C.
DATE PLACE AND & OTHER CIRCUMSTANCES OF

OCCURRENCE
On or about April 8, 2011, claimant was placed by the public entities

named herein in the custody and control of Matthew Brooks where he
remained until approximately March 1, 2014. The placement was
located at 23 Texas Avenue, Monmouth Junction and/or 1 Jersey
Avenue Monmouth Junction, New Jersey. Claimant was assaulted and
sexually assaulted, abused, and victimized repeatedly during this period
of time by Michael Brooks. Claimant lived in a dangerous and unsafe
environment. The public entities and its employees failed to exercise
reasonable care to make sure claimant was in a residential setting that
was free from physical and psychological abuse. It is contended that
the public entities identified in this Notice of Claim, including its
agents, representatives and employees, failed to exercise reasonable
care in the evaluation of the claimant's placement with Michael Brooks.
The defendant public entities and its agents, representatives and
employees failed to exercise reasonable care in the performance bf their
job responsibilities including but not limited to supervising, monitoring
and taking care of the claimant's health, wellcbeing and physical safety.
It is also contended that the defendant and/ or its employees engaged in
willful wanton misconduct. It is also asserted that the agents,
representatives and employees of the public entities failed to comply
with state and federal statutes, state and federal regulations and the
policies of the agencies.
It is also contended that the locations of claimant's placements were an

unsafe condition of public property due to physical and psychological
abuse that claimant was subjected to.
Defendants are also lia,ble'for the plaintiff's injuries because they
violated his civil rights because these state and county entities created
a danger and violated her state and federal civil rights.
D.
GENERAL DESCRIPTION OF INJURIES DAMAGE OR LOSS
The claimant sustained multiple injuries and trauma. The claimant

sustained physical injuries from assaults, battery and sexual assault
and battery. The claimant has also sustained emotional harm. The
patient has received and requires psychological/psychiatric treatment
and counselling.
E.
THE AMOUNT CLAIMED TO DATE IS:

Fifty ($50,000,000.00) million dollars.*
Attorneys for Claimant:
Please note that I will not be able to obtain any more detailed
information concerning this claim until such time as the agencies have
produced the records requested from the public entities in OPRA
requests.
Dated: February 19, 2015
Mar. 19. 2015 12:46PM
Monmouth North litigation
No. 7534
P. 2
INITIAl NOTICE OF CLAIM FOR DAMAGES AGA)NST THE STATE OF .NEW JERSEV
FOWARD TO: DEPAI\iMENT OF THE TREASURY
DIVISION OF RISK' MANAGEMENT
20 WEST 51'AT ST!IEI!l', PO BOX 62.0
TRENTON, NEW JERSEY 0862S.o620
PHONE: (609} 292-4<147 -~
roRM MUST BE FILED WITHIN 90 DAYS OFTHEAC:CIDENT OR YOU MAY FORFEIT YOUR RIGHT
- '1,
Be \- J\~ \\ -- -- -.. -.. 33:BCL~~\derrutwtt~----
NAME 01' CLAIMANT _: 1\lR OR MRS.) cm~Le ONE
STREET ADDRESS
. \Seotwta~c t'1~ 1 \q]~
CITY
DATE-aF BIRTH
NS
\U\ciheriDWtL
Ollif:C1
STATE
ZIP CODE
-"1\4-C1DJ- ll'}
SOCIAL SECURITY NUMBER
DAYTIME PHONE NUMBER
2. IF NOTICES AND CORRESPONI1ENCE-IN CONNECTI0N WITH !HIS CLAIM ARE TO BE $!:NT TO A PERSON
OTHER THAN ClAIMANT, COMPLETE ITEM#~.
NAME OF PERSON
STREET ADDRESS
CITY
.TELEPHONE NUMBER
RELATIONSHIP TO CLAIMANT:
STATE
ZIP CODE
OOTHER~~-~------'---
OATIORNEY
{SPECIFVJ
nttJ;Tl~~:ffiri~~:y~~i~C:EOR ACCIDENT:N \ ~
. . OAliAI'JO TIME
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sTA'TE VEHJCtEDRiVER'S NAME
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ACCIDENT OR OCCURRENCE; IF A DIAGRAMWllL ASSISTYOUR
sePAAAfE SH.Etr ,c\ND A'rTACH ITTO THIHORM.
EX~LANATION, USE A
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-,-~Mar.19.
2015-12:46PM--:-Monmouth North litigation
No. 7534
P. 3
INITIAl NOTICE OF ClAIM FoR~OAMAGES AGAiNST T'HE STATE OF NEW JERSEY

FOWARO TO: DEPARTMENT OF THE TREASUR:Y
DIVISION OF RISK MAN~GEMENT
:lOWEST STATE STREET, PO. BOX 620
TReN'TON,-NEW~JERSEY 08625-0620
PHONE: (609) 2.92-4347
ZIP CODE
~: IF NOTICES AND CORRESPONDENCE JN CONNeCfiON WITH THIS ClAIM ARE TO BE SENT TO A PEAS ON
OTHER THAN CtAIMANT, COMPLETE ITEM #2. .
ii!AME OF PERSON
StREET ADDRESS
.. tgtEPHON!; NUMBER
RELATIONSHIP TO ClAIMANT:
ZIP' CODE
STATE
CIT'{
OATTORNEV
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(SPECIFY)
3A: CIRCUMSTANCES REGARDING THE OCC~RRENCE OR ACCIDENT:
tfil.u"~aj{LxJmA ,. n\rurl~Y\Jm~
DATE S\ND TIME
STAlE Vl'HIClE DRIVER'S NAME.
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LOCATION {MILEPOST, NEAREST EXIT, CROSS STREET)
CITY
STATE
.. STATE' PLATE# AND VI'HlCLE DESCRIPTION

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. 3a::DESCRlllE THE ACCIO.ENt OR OCCURRENCE: IFA DIAGRAM WIU ASSIST YOUR EXPlANATION, USEA .
. .SBPARATE S~EEr AND A7TACH ITTQ THIS FORM.
.
;See 8ssoG\ared CC4\e *
__
Mar. 19. 2015 !2:46PM
Monmouth North Litigation
No. 7534
P. 4
3C. STATE THE NAME AND ADDRESS OF THE STATE AGENCY Oil AGENCIES THAT YOU CLAIM CAUSED YOUR
DAMAGE.
_. . ,Sec Bttathmenl H
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STATE THE NAMES OF STATE EMPLOYEES WHOM YOU CLAIM WERE AT FAULT, INCLUDING ANY.......... .. ..... ----
)N~ORMATION'!HA'r Wltt:ASSIST 1f'fiNDENTlFVINt:rAND10CATil'lG'TREfvf
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3D. STATE THI: NEGLIGENCE OR WRONGFUL A'crs OF THE STATE AGENCY AND STATE EMPLOYEES WHICH
CAUSED YOUR DAMAGES.
Gee.
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3E.STAT THE NAME AND ADDRESS OF AlL WITNESSES TO THE ACCIDENT OR OCCURRENCE
~,
. 3F.STATE THE NAMES Of ALL POLICE OFFICERS AND POLICE DEPARTMENTS WHO INVESTIGATED THIS
ACCIDENT. PROVIDE POliCE REPO.RT CASE NUMBER, IF AVAILABLE.
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4A.. ~I.AIM FOR DAMAGES (CHECK APPROPRIATE !!lOCK}:

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Mar. 19. 2015 12:48Piv1
No. 7534
P. 11-.
48. II' YOU CLAIM PERSONAl INJURY:

... (1) DESCRIBE YOUR INJURIES RES'dlTING PROM TH!.S-ACCIDENT OR OCCURRENCE.
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(2,) 00 YOU CLAIM PERMANENT OISABitiTY RESUlTING fROM l'HIS INJURY:
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IF Yes, DESCRIBE THE INJURIES BELIEVED TO BE PERMANENT.
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[3) FOR EACH HOSPITAl:; DOCTOR OR OTHER PRACHTJONERRENOERINGTREATMENT, EXAMINATION OR
. .. DJAC:lNOsriCSERVIE:ES,.5rATE:
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. NAME OF HOSPITAL,
DkTES OF
AMOUNT OF AMT. PAID OR PAYABLE
DOcTOR OII:OTHER
ADDRESS
TREATMENT CHARGEiO
BY OTHER SOURCE; I.E.
' FA1LITY ..
Oil SEIMCE
[)ATE
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.. . . . .. (4)1FYOV ci.AtM LOSS OF WAG1: OR INCOME AS A
RESUL~~Ol' l'HE INJURY STATE:

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. . . ' NAME OF EMPlOYER
ADDRESS OF EMPLOYE!!
..vtiUR ocqiPATJON
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DATE YOU BECAME EMPLOYED
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!lATE bF ABSENCE FROM WORK

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~- ~O~AllOSSWAGe5 T9 DATE
IF S'r'lll OiJT, EXPECTED DATE OF RETURN
. .. rHJ;E! lHOUR ClAIMED LOSSOF INCOME ARISES FROM SELF-EMPLOYMENT OR OTHER THAN WAGE,.
.. . J\TTACfjACALCUtATiON SHOWING THE I!~ IS OFYOUR CAlCUlATION OF LOST INCOME.
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Mar. 19. 21l-15 12:4$PM
----No. 7534-P ..12--,_ -
($)SET FORTH ANY AND AI;L OTHER lOSSES OR-OAM:i\GE-ClJI;IMfD I.W_VOU.
0ee Oinillment u-
, 4(;. IF YOU CLAIM:i'ROI'ER'rV' DAMAGE:
(1) OE:$CRIBE nt~ PROPERT-Y OAMAGEO.
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(a) DATE PROPER'rV' ACQLiiREP.....;___;~----------!.'

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. {4) COST -GFPHOPERTY$_ ___;__ __..__ _ _ _ _ _ _ _ _ __
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(5) VALUE OJ' PROPERTY Ai UME OF ACCIDENT$.._._ _ _ _ _ _ __
- (6] DESCRIPTION OF DAMAGE.
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-. (7)-HAS fHE D,AJii1AGE BEEN REPAIRED? DYES
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IF SO, BVWHOM, WHEN AND COST OF REPAI.Rs.
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;, ._ (8)1'\TfA(;H ACHI'STIMATE OF REPAIR COSTS TO THIHORM. -
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FORi'k 1111 DEIAILA~l OTHER ITEMS OF LOSS DR DAMAGES ClAIMED BY YOU AND THE METHOD BY
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No. 7534 P. 14.
5.-THE AMOUNT OF Tlif-CLAlM-$ - - - - - - - - 6. HAVE YOU MADE A ClAIM AGAU<IST ANYONE ElSE FOR ANY OF THE LOSSES OR EXPENSl!S ClAIMED IN
THI$ Ni:lnCE'T
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iF. y5, SET1'0RTH THE NAME-ANnAD9RES5 OF ALL PERSONS A'ND INSURANCE COMPANiES AGAINSi .
WHOM YOU HAVEMADESUCH CtAIMS:
: . . 7.:.ARE-ANYcOfiHt
LOSSES OR EXPENSES CLAIMED HEREIN COVERED BY ANY POLICY OF INSURANCE?.
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f'QRc~t:;-suC-ffPOLIO', STATE THE NAME.AND ADDRESS OF THE INSURANCE COMPANY, POLl~ NUMBER
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. - . B~HAV~ YOU ReCEIVED OR AGREED to RECEIVE ANY MONEY FROM ANYONE FOR THE DAMAGES ClAIMED .
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: , : .. ' (iJ COPiES OF lftN!li:EDJlU.isl'ORt:ACH M~DICAL EXPENSEANO OTHER lOSSES AND EXPENSES CLAIMEn. . . , ::~ :
, . . (2)F!Jlicepfes OFAttAPPRAISALSANo_ ESTiMATES Oi> PROPERTY DAMAGE ClAIMED BY YOU
. , .. ' . (3} COPIES OF ALL WRIITEN REPORTS OfALl EXPERT W!TNESSES.AI\ID TREATING PHYSICIANS.
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~RO~ YOUR EMplOYER VERlfYING YOUR LOST WAGES. If SELF-EMPLOYED, A STATEMENT
sli6WING 'me cALcuLAnoN OF vouRcLAIMEDLOs'r INCOME.
.. iHe~ka~ teRriFYTHiWTHf;FOREGOlNG STATEMENTS MADE BY ME ARE TRl,JE. THATTHE ATIACHED ..
$TA1'EMENTS, BILLS, REPORTSANPOOCUMENTS AilE TH~(iNLY ONES KNOWN TO M!i TO BE IN EXISTENCE.' ,..
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-.,-----No. 7534_P. !5---..
Monmouth North Lifigat ion
Mar. 19. 2015 I2:49PM
- 5. TEILAMOUNT OHH~ CLAIM$_;.._,.___,_ _ _ __

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1;,, HAVE YOU MADE AC[#M-AGAINST ANYONE-ElSE FOR ANY OFTHeLOSSES OR EXPENSES ClAIMED IN, : . ' : _
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THiS NOTICE?
-BYES
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IF. YEs, SET fOilllt THE NAME ANO ADDRESS<lF ALL PERSONSAND INSURANCE COMPANIES AGAtNST -_- ..
:wfib!'v1YOU H~.EMAilfSucH clAiMS:
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01' TfiELossi:S OREXjiENSES ClAIMED HEREIN COVE'REO BY ANY POLICY OF INSURANCE? - . , :

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STATET~E NAMIEANDADORESS Of THE INSURANCE COMPANY, POLICY NUMBER
. -:F.riR:I:A-cH SUCH pOLICY,

AN[1 BENEFITSPAJ.IlORI'AYAilLE.
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. ' _.. .8.-H,<\VE-VQUllECElVED OR AGREED i'o RECEIVE ANY MONEY FROM ANYONE FOR THE DAMAGES CLAIMED
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. IF YES; SET FORTH THE DETAtlOF SUCH AGREEMENT.
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> _ (2) ~UltCCiPJES QF All APPI\AlSAts AND ESTIIV1ATES QF PROPERTY DAMAGE ClAIMED BY YOU .
. i : ._. {~) COPI~S j)F *WR.trrEN REPORTS oi= All EXPERT WiTNESSES AND T~ATING Pi-IYSICIANS.
l4}AlWER FROMYOUR EMPLOYER VERIFYINGYO~Il LOsTWAGE$.1F SELF-EMPLOYED, A STATEMENT

. SHPWINGtHEt:ALCUl.ATJON OFYOUR CLA1MED lOSTINCOME.
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GOLDSTEIN & GOLDSTEIN, LLP

60 Evergreen Place, Ste. 502
East Orange, NJ 07018
(973) 675-8277
Attorneys for the Claimant
KRISTY POWELL,
vs.
STATE OF NEW JERSEY,
and DEPARTMENT OF
CHILDREN AND FAMILIES,
its agents, servants and/or
employees, individually,
severally and jointly,
TORT CLAIMS NOTICE
State ofNew Jersey

Department of Treasury
P.O. Box 620
Trenton, NJ 08625
a. Name and address of claimant:
Kristy Powell
490 4th Ave., Apt. 413
Newark, NJ 07107
It is requested that notices be sent to Goldstein & Goldstein, LLP, attorneys for Kristy
Powell, at 60 Evergreen Place, Ste. 502, East Orange, NJ 07018.
b. A claim is made for injuries sustained in an accident, which occurred on February 12,
2015. The claimant was walking in the parking lot of the Parkside Pre-School II at
354 Park Ave., in Newark, New Jersey, when she was caused to slip and fall on ice
and/or snow.
c. So far as it may be known at this time the claimant suffered the following injuries:
right knee, lower back, both wrists, legs
e. The name of the public entity causing the injury is State of New Jersey, and the
Department of Children and Families by and through its agents, servants and/or
employees.
f. The amount claimed as of the date of presentation of this claim, including the amounts
of any prospective injury, damage or loss is One Million ($1,000,000.00) dollars. The
basis of the computation ofthe amount claimed is the nature and extent of claimant's
inj~~/
MICHAELGOLDSTEIN, ESQ.
Attorney for Claimant
Dated: March 19, 2015
INITIAL NO"FJCE-GF CLAIM FOR DAMAGES AGAINST THE STATE OF NEW JERSEY
FOW:A:RD TO:
TORT AND CONTRACT UNIT

DEPARTMENT OF THE TREASIJRY, BUREAU OF RISK MGMT.
POBOX620
TRENTON, NEW JERSEY 08625
PHONE: (609) 292-4347
FORM MUST BE FILED WITHIN 90 DAYS OF THE ACCIDENT OR YOU MAY FORFEIT YOUR RIGHT
COston
Joseph
See Attachment A
LAST NAME
FIRST
DATE OF BIRTH
3()..1 0 Gentner Road

STREET ADDRESS
2.
MAILING ADDRESS IF OTHER THAN STREET ADDRESS
Fair Lawfl-
NJ
07410
See Attachment A
CITY
STATE
ZIP CODE
IF NOTICES AND CORRESPONDENCE lrq-CONNECTION WITH THIS CLAIM ARE TO BE SENT TO A PERSON OTHER THAN.
CLAIMANT, COMPLETE ITEM #2.
Beth G. Baldinger
Mazie Slater Katz & Freeman, LLC
NAME
MAIUNG ADDRESS
Roseland
NJ
07068
CITY
STATE
ZIP CODE
103 Eisenhower Parkway
ATTORNEY AT LAW [gf OR

EXPLAIN RELATIONSHIP
THE OCCURRENCE OR ACCIDENT WHICHGAVE R!SE TO THIS CLAIM:

3a.
3/2009 through 11/2013
See Attachment B
DATE
TIME
b. DESCRIBE THE LOCATION OR PLACE OF THE AcCIDEN'i'OROCCURENC-E.

Patterson and Elmwood Park
See Attachment B
MUNICIPALITY
EXACT LOCATION OF THE OCCURRENCE
c. DESCRIBE+l6WIHE ACCIDENT OR OCCURENCE HAPPENED: IF A DIAGRAM WILL ASSIST YOUR EXPLANATION, PLEASE USE
"J:HE REVERSE SIDE OFTHIS FORM.
The Department oKhildren andJ'amilies, Division of Youth and Family Services (now known as the Division of Child Protection
and Permanency) lts caseworkers. supervisors. and/or others working on their behalf {identities currently unknown) were
negligent and vlmated the rights of claimant's children as more fully described In Attachment B.
-d. STATE THE NAMEANDJ\DDRESS.OFTHE STATE AGENCY OR AGENCIES nlATYOU CLAIM CAUSED YOUR DAMAGE.
Department of Children and Families, Division of Youth and Family "Services (now the Division of Child Protection and Permanency)
SO East'State Street. Trenton, New Jersey 08625. as well their local offices who were assigned and responsible for claimant's
_-&.,.lldren while they were living in Patterson (Passiac County) and then in Elmwood Park (Bergen County), N.ew Jersey.
STATE THE NAMES OF STATE EMPLOYEES WHOM YOU CLAIM WERE AT FAULT, INCLUDING ANY INFORMATION THAT WILL
ASSIST IN INDENTIFYING AND LOCATING THEM.
The names of all DYFS/DCPP employees and/or agents who were at fault are currently unknown and subject to discovery.
However, those with knowledge include but are not limited to Cristina Keresztes, Lydia Tatekawa, and Ayesha Ware.
e. SJATHHE NEGLIGENCcORWRONGFULACTS OF THE STATE AGENCY AND STATE EMPLOYEES WHICH CAUSED YOUR
DAMAGES.
see Attachment B.
f. STATETHE NAM AND ADDRESS OF ALL WITNESSES TO THE I'.CCIDENT OR OCCURRENCE.

Claimaint's children; DYFS/DCPP employees and agents; those who provided medical assessment and services to claimant's
children: S
O'
R , Sr., S.R.: T.R. (addresses unknown): Members of the City of Patterson and Township of
Elmwood Park Police Departments Qdentltles unknown!: and others whose Identities to be revealed In djscove[)l.
g. STATE THE NAMES OF ALL POLICE OFFICERS AND POLICE DEPARTMENTS WHO INVESTIGATED THIS ACCIDENT,
The Bergen County Prosecutor's Office is currently irr.estlgating this matter in connection with charges brought against O'Neil
Reid, Sr. The Chief Assistant Prosecutor is Catherine Fantuzzi,. See-Also. response to 3(f) above.
4a. CLAIM FOR DAMAGES (CHECK APPROPRiATE BLOCK):
PERSONAL INJURY
OTHER- EXPLAIN IN DETAIL
PROPERTY DAMAGE
---------------------------------------------------
b. IF YOU CLAIM PERSONAL INJURY:

(1) DESCRIBE YOUR INJURIES RESUlTINGHlOM THIS ACCIDENT OR OCCURRENCE.
Each of the miner children have suffered physical and psychological InJuries as more fully setforth in Attachment C.
(2)
DO YOU CLAIMJ'ERMANENT DISABILITY RESUL'l'!NG FROM THIS INJURY:

~
YES
NO
;-
If YES, DESCRIBE THE INJURIES BELIEVED TO BE PERMANENT,

Psychological injuries from physical, emotional and sexual abuse are claimed to be permanent.
(3) J"OR EACH HOSPITAL, DOCTOR OR OTHER PRACTITIONER RENDERING TREATMENT, EXAMINATION OR DIAGNOSTIC
SERVICES, STATE:
NAME OF HOSPITAL,
DOCT0R OR OTHER
FACILITY
ADDRESS
DATES OF
TREATMENT OR
SERVICE
AMOUNT OF AMT. PAID OR PAYABLE BY

CHARGETO OTHER SOURCE SUCH AS
DATE
INSURANCE
See Attachment C.
(4) IF YOU ClAIMLOSSOFWAGEOR INCOMEASARESULTOF THE INJURY STATE:

Unknown at the current time.
NAME OF EMPLOYER
ADDRESS OF EMPLoYER
YOUR OCCUPATION
RATE OF PAY
DATE OF ABSENCE FROM WORK
TOTAL LOSS WAGES TO DATE
IF STILL OUT, EXPECTED DATE OF RETURN
NOTE: IF YOUR CLAIMED LOSS OF INCOME ARJSES FROM SELF-EMPLOYMENT OR OTHER THAN WAGE, ATTACH A
CALCUlATION SHOWING THE BASIS OF YOUR CALCULATION OF LOST INCOME.
(5) SET FORTH ANY AND ALL OTHER LOSSES{)R DAMAGE CLAIMED BY YOU.
To b
lied.
C. IF YOU CLAIM PROPERTY DAMAGE:

_(1) DESCRIBE THE PROPERTY DAMAGED.
Not a
licable.
[2) THE PRESENT LOCATION AND TiME WHEN THE PROPERTY MAY BE INSPECTED.
(3) DATE PROPERTY ACQUIRED.
(4) COST OF PROPERTY
---------------------
(5) VALUE OF PROPERTY AT TIME OF ACCIDENT: $
-----------
(6) DESCRIPTION OF DAMAGE.
(7) HAS THE DAMAGE BEEN REPAIRED?
--------
IF SO, BY WHOM, WHEN AND COST OF REPAIRS.
I
(8) ATTACH EACH ESTIMATE OFllEPAIR COSTS TO THIS FORM.
(9} SET FORTH IN DETAIL THE LOSS CLAIMED BY YOU FOR PROPERTY DAMAGE.
II
II
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d. SET FORTH IN DETAIL ALL OTHER ITEMS OFLOSS OR DAMAGES CLAIMED BY YOU AND TH<; METHOD BY WHICH YOU MADE
THE CALCULATION.
5.
THE AMOUNT OFTHE CLAIM. _$30,000,000 (Thirty Million Dollars)
6.
HAVE YOU MADE A CLAIM AGAINST ANYONE ELSE FOR ANY OF THE LOSSES OR EXPENSES CLAIMED IN THIS NOTICE?
No
IF'>:'ES, SET FORTH THE NAME AND ADDRESS OF-ALL PERSONS AND INSURANCE COMPANIES AGAINST WHOM YOU HAVE
MADE SUCH CLAIMS:
7. ARE ANY OF THE LOSSES OR EXPENSES CLAIMED HEREIN COVERED BY ANY POLICY OF INSURANCE?
Medical care and treatment expenses are covered by health Insurance and other benefits.
FOREACH SUCH POLICY, STATE-THE NAME AND ADDRESS OF THE INSURANCE COMPANY, POLICY NUMBER AND BENEFITS
PAID OR PAYABLE
Toi>e su
8.
lied.
HAVE YOU RECEIVED OR AGREED TO RECEIVE ANY MONEY FROM ANYONE FOR THE DAMAGES CLAIMED HEREIN?
YES
jgJ
NO
IF YES, SET FORTH THE DETAIL OF SUCH AGREEMENT.
9. THE FOLLOWING ITEMS MUST BE SUBMITTED WITH THIS-NOTICE:

(1) COPIES OF ITEMil:ED BJLLS FOR EACH MEDICAL EXPENSE AND OTHER LOSSES AND EXPENSES CLAIMED.
(2) FULL COPIES OF ALL APPRAISALS AND ESTIMATES OF PROPERTY DAMAGE CLAIMED BY YOU.
{3) COPIES OF ALL WRITTEN REPORTS OF ALL EXPERT WITNESSES AND TREATING PHYSICIANS.
(4) A LETTER FROM YOUR EMPLOYER VERIFYING YOUR LOST WAGES. IF SELF-EMPLOYED, A STATEMENT SHOWING THE
CALCULATION OF YOUR CLAIMED LOST INCOME.
I HEREBY CERTIFYTHATTHE FOREGOING STATEMENTS MADE BY ME ARETRUE. THATTr:E ATTACHED STATEMENTS, BILLS, REPORTS AND
DOCUMENTS ARE THE ONLY ONES KNOWN TO METO BE IN EXISTENCEATTHIS TIME. I AM AWARETHAT IF ANY STATEMENT MADE
HEREIN IS WILLFULLY FAlSE OR FRAUDULENT, THAT I AM SUBJECT TO PUNISHMENT PROVIDED BY LAW..
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lc1I \ '5DATE
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CLAIMANT ORPERSON FILING ON BEHALF OF CLAIMANT
NOTICE OF CLAIM
To:
State of New Jersey
Office of the Attorney General
P.O. Box080
Trenton, New Jersey 08625

P.O. Box 729
Trenton, NJ 08625
Andrew Patten, hereby presents this claim pursuant to Sections 59:8-1 et seq. of the New
Jersey Statutes.
1. The name and address of the claimant is as follows:
Andrew Patten
313 Tiniber Line Drive
Mount Laurel, NJ 08054
DOB: 11/28/88
2. The address to which the claimant desires correspondence regarding this claim to be
sent is:
Adam M. Kotlar, Esquire
1913 Greentree Road
Cherry Hill, New Jersey 08003
3.
Circumstances regarding the Occunence or Accident:
On March 29, 2015, Claimant was lawfully at the residence of Susan Manuel, 2 Camelia
Lane, Mt. Laurel, NJ 08054 when Jordan Long, an invitee to the property, punched
claimant in the face three times.
4. Due to the above-mentioned circumstances, claimant has incurred the following:
Broken jaw.
5. The doctor who treated claimant's injuries is:

Dr. Wallace
Virtua Hospital
90 Brick Road
Marlton, NJ 08053
'
6. So far as is !mown to the claimant at the date of this claim, the claimant has incurred
damages: Pending.
7. The name of the public employee causing the above described injury and damage is:
Still under investigation
8. As a consequence of claimant's injuries, claimant has lost income in the sum of N/A
9. Claimant hereby demands damages in the amount of$ unspecified at this time.
, . r .
Dated: 4/15/15
9!:ouM '(?~ ~-' ~ cd.

/06'/J ?fad'~ ~
Of&~ QJjl"ew ~ 08/16'0

QT~.., (sstf)
o.91-o8oo_,. r:fft~ (sstf) 7.94-:J/J:to
LOlliS CHARLES SHAPffiO
SAMUEL L. SHAPffiO
CERTJFIED CRIMINAL TIUAL ATTORNEY
ATTORNEY AT LAW
COUNSELOR AT LAW
!940(ADMI1TEDTONJBAR)-l996
LL.M.1N TRIAL ADVOCACY

MEMBEROFNJ ANDPA.BARS
Email: ~.llim.i@.PJ~
Website: ww\v.louischnrl!~ssh.mlli:o.cmll
April20, 2015
VIA CERTIFIED MAIL (RRR)

See Attached Service List
Re:
Victoria Faniel, et al. v. New Jersey Department of Children and

Families, eta!.,- Tort Claim Notice (DOI 1/21/15)
Dear Sir!M:adam:
Enclosed for service upon you at this time is a copy of a Tort Claim Notice on behalf of
Claimant(s) in this matter.
I
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Enclosure
Ms.. Victmia Faniel (w/encl.)
cc:
SERVICE LIST
New Jersey Department of Children and Families

Allison Blake, Ph.D., L.S.W., Connnissioner
20 W. State Street, 4'h Floor, P.O. Box 729
Division of Child Protection and Permanency
50 E. State Street, P.O. Box 717
Cumberland East District Office
415 W. Landis Avenue, 1'' Floor
Vineland, New Jersey 08360
Ms. Jaime Maronski
415 W. Landis Avenue, !''Floor
Ms. Haleema Lake
415 W. Landis Avenue, 1" Floor
Mr. Daniel Melendez

Ms. Tonia Dailey
Ms. Tierra Walker
Cmnberland East District Office
Ms. Susan Langan

415 W. Landis Avenue, 1st Floor
NEW JERSEY TORT CLAIM NOTICE AND

CLAIM FOR DAMAGES AGAINST THE NEW
JERSEY DEPARTMENT OF CHILDREN AND FAMILIES;
DIVISION OF CIDLD PROTECTION AND PERMANENCY ("DCP&P");
DCP&P CUMBERLAND EAST DISTRICT OFFICE; JAIME MARONSKI;
HALEEMA LAKE; DANIEL MELENDEZ; TONIA DAILEY; TIERRA
WALKER; SUSAN LANGAN; AND/OR JOHN/JANE DOE(S) DCP&P
EMPLOYEES, OFFICERS AND SUPERVISORS
1. Claimant(s ):
Victoria Faniel, 1027 Florence Avenue, Apt. 14J, Vineland, New Jersey 08360 (DOB
5/8i91; SS#
, individually and on behalf of her children, J.F., J.H., and
A.M., and/or other Claimants who may have been affected by the removal of children
in the matter described below.
If notices and correspondences in connection with this claim are to be sent to a person
other than claimants, complete item #2.
2.
Louis Charles Shapiro, Esquire

Louis Charles Shapiro, P.A.
1063 Vineland, New Jersey 08360
(856) 691-6800; FAX# (856) 794-3326
E-mail: sbrul.@~rmRngy.mlt
Relationship to claimants: Attorney at Law (xx)
The occurrence or accident which gave rise to this claim:

3a. 1121115 and times and dates thereafter
(Date)
b. Describe the location or place of the accident or occurrence
Vineland, New Jersey (Municipality)
c. Describe how the accident or occurrence happened:

Claimants will refrain from providing significant details based on confidential
discovery received in connection with a case against Claimant Faniel and others under
Docket No. FN-06-89-15, which is currently pending in the Superior Court of New
Jersey, Chancery Division, Family Part. Claimants can and do allege that on Jan nary
21, 2015, Claimant Faniel's two sons, J.F. and J.H.. were removed from her care, by
way of a DODD removal, and her ability to see her daughter, A.M., has been impaired
and restricted as a result of said removal and ongoing litigation initiated by
Respondents herein. The alleged basis for the removal ofthe children from Claimant
Faniel's custody was the detection of an odor of marijuana in Claimant Faniel's home,
the alleged observation of marijuana in the home, and Claimant allegedly being nuder
the influence of marijuana at the time ofthe visit by one or more ofthe Respondents.
Respondents maintained that the above, as well as other facts contained in confidential
discovery, created an imminent danger or a substantial risk of harm to the children
necessitating removal. On the day in question, Respondents compounded the damage
to Claimant(s) by having Claimant Faniel arrested and charged by the Vineland Police
Department. Respondents proceeded by way ofVerified Complaint and Order to Show
Cause on or about January 23, 2015 before a Superior Court Judge in Cumberland
County. In so doing, the Respondents procured an Order from the Superior Court
Judge upholding the removal ofthe children relying on, inter alia, the above allegations,
as well as an unproven allegation from another partv that Claimant Faniel and/or
others were selling marijuana out of her home. In so proceeding against Claimant
Faniel and/or others who may have an interest in this action (and Claimant reserves the
rightto name additional Claimant(s) in this matter), Respondents removed the children
from Faniel's care and/or separated Faniel from her children in the face of clear
precedent from New Jersey appellate court decisions which provide that marijuana use
alone does not necessarily form an appropriate basis justifying the removal of children
from the care of a natural parent. See N.J. Div. of Child Prot. & Permanency v. M.C.,
435 N.J. Super. 405 (App. Div. 2014); N.J. Div. of Child Prot. & Permanency v. A.L.,
213 N.J. 1 (2013); N.J. Div. of Child Prot. & Permanencyv. T.R., Docket No. A-104412T3 (App. Div. Nov. 10, 2014); N.J. Div. of Child Prot. & Permanency, Docket No. A3477-12T3 (App. Div. Dec. 19, 2014); G.S. v. Dep't of Human Servs., Div. of Youth &
Family Servs., 157 N.J.161 (1999); N.J. Div. of Youth & Family Servs. v. V.T., 423 N.J.
Super. 320 (App. Div. 2011); N.J. Div. of Child Prot. & Permanency, Docket No. A4545-12T3 (App. Div. Dec. 23, 2014); N.J. Div. of Youth & Family Servs. v. O.C..
Docket No. A-2124-12T2 (App. Div. April 24, 2014) and/or. other authorities.
Furthermore, Respondents at the time ofthe removal of the children were on notice of,
and/or knew or should have known about, the risk of unnecessary and unconstitutional
removals of children from prior federal litigation involving the Division of Youth and
Family Services arising out of Cumberland County in a case captioned as Bostrom v.
:OYFS, et al., Civil Action No. 11-1424 (JBS). As a result of Respondents' removal of
the children, Claimant Faniel and/or other Claimants have been deprived of the
children, which deprivation continues to this day, as Respondents' litigation remains
ongoing and Claimant(s)' damage is increasing.
d. State the name and address of the State agency or agencies that you claim caused your
damages.
New Jersey Department of Children and Families, 20 W. State Street, 41h Floor,
P.O. Box 729, Trenton, New Jersey 08625; Division of Child Protection & Permanency,
50 E. State Street, P.O. Box 717, Trenton, New Jersey 08625-0717; Cumberland East
District Office, 415 W. Landis Avenue, 1'' Floor, Vineland, New Jersey 08360.
State the name of State employees whom you claim were at fault, including any information
that will assist in identifYing and locating them.
Those individuals whose names are set forth in the caption of this Tort Claim
Notice, John/Jane Doe(s) DCP&P employees, officers and supervisors, and/or other
state actors who may be revealed in discovery and investigation.
e. State the negligence or wrongful acts of the agency and employees that caused your
damage.
The negligence and/or wrongful acts are described above. The claims in this
matter are cognizable under. in addition to various New Jersey state constitutional
provisions and statutory enactments, New Jersey common law, including but not
limited to, negligence, negligent and/or intentional infliction of emotional distress,
negligent hiring, supervision and retention in employment, defamation, abuse of process
and/m malicious prosecution, invasion of privacy.
f. State the name and address of all witnesses to the accident or occurrence.
The known witnesses are set forth above, and are named in discovery which is
currently subject to a protective order. Claimant reserves the right to name additional
state actors as may be revealed in discovery and investigation.
4. Claim for Damages (check appropriate block)

[ XX ] Personal injury
] Property damage
[XX ] Other- explain in detail: See theories of recovery set forth herein,
including but not limited to damages for emotional distress on behalf of adult and
minor Claimants, amount(s) necessary to retain counsel to defend against legal action
initiated by Respondents, and/or punitive damages, on behalf of both adult and/or

minor Claimants.
5. Ifyou claim loss ofwages or income as a result ofthe injuries detailed herein, please state
the amount of the claim below:
Unknown at this time, but Claimant reserves the right to supplement.
6. Have you made a claim against anyone else for any of the damages claimed
in this notice? No.
If yes, set forth the names and address of all persons and insurance companies against whom
you have made such claims. Not applicable.
7. Are any of the losses or expenses claimed herein covered by any policy of insurance? For
each such policy, state the name and address of the insurance company, policy number and
benefits paid or payable.
Claimant does not believe that any of the claims asserted herein are covered by
insurance.
8. Have you received or agreed to receive any money from anyone for the damage
claimed herein? If so, set forth the details of such agreement. No.
CERTIFICATION
I hereby certify that the foregoing statements made by me are true to the best of my
knowledge, information and belief. I am aware that if any of the foregoing statements made
by me are wilfully false, I am subject to punishment. ...........
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(... claunantand/or PersonFiling'on behalf of

Claimants
Ju1. 14. 2013 10:58AM

CLAIM FOR DAMAGE,
INJURY, OR DEATH
'
No.L810
P. 2
FORM APPROVED
OM9 NO.1 10S.OOOB
INSTRUCTIONS: FleaseteO<i cororvny rho rnslrucUons on ille

reverne o](l!) ~nd :~~upply Information requested Oh l;oth sldos of this
((lilT). UJ;a ad'd!llonal sheel{s) if neceBsBry, Soo rl;lwrsa side ror
additfonallrmlruotlong.
or d<!ll'l'tMt, :-od dal!lUUI~\lptlrtlO!llll raprewnlalfv!l' i1 any.

(Soo ln-swctloos on ravsrsa}. Numbe(, Street, CIIY, $1a\a and Zip coda.
1. Subll'lit to /I.Wfopt"fate Federol Ag~ncy;
2. Nama. IJddfflSS
Depanment of Children and Families

Camden North LO #766
1 01 Haddon Avenue 4Ul & 5th eloors
Camden NJ 08101
lll Bro. Algie deWil! 32

86 Vance Avenue
Sicklerville, NJ 08081
1: DATE OF BIRTH
3. TYPE OF EMPlOYMefr
MILITARY
CIVILIAN
01/25/1963
5. MARITAL Sl'ATUS
b. DATE AND DAY OF ACC)O~'f
05/2112013
1. TIME {AM. OR P.M.)
6, BASIS OF CLAIM (Sta!aln detail ttl a known (<Jcl$ and cli'CIJIYISlllll~ al\.e.fldlng lha damage, InJury. ordcilth, ldenth'ylng persons nnd property ln'Volv~>d, tru: pi: a<-~ of OWJITetlliil and
11\e tause ~lerMf, t}$e :flddllfl?M{ p~M !f neoossary).
SW Ebo11y Childers. did willingly and knowingly prohlb\1 vlsltaUon wilh daughter although no reatralning order Is In place.
Original restraining order issued in Philadelphia eight [ 8] years ago In violation of 42 U.S.C. 1983 [deprivation of rights) !his
filing Is addiUonallo complaint filed 5/31/11 in fha City of Philadelphia.
PROPEn'fY bAMAGr:!
N/tMEAND ADDRESS OF OWNER, !F OTHER Ttw-1 CtAIMNff (Nvm!J~;~r, -$\fOOl, City, Sta!e, and Zip <Ailn),
SRIEFLY UESCRTBE THE PI'{OPERlY, NATURE AND EXTENT OF THE OAMAGE AND THE lOCATION OF WHERE THE PROPERlY fl.fAY IJE INSPECTED.
{Sea lna!ructlona oo ravnroo .u!da).
Undue emotional stress, psychological abuse on both the part of Father and Daughter esp. Daughter who has endured 16 yrs
of unnecessary placement In various CPS agencles.
flJiRSONAllNJURYIWRONOFUL DEJ\"(t-1
10.
S'rATE ll-IE NAT\JRE: ANO EXTE~T Or: EACl-IINJURY OR CAUSE: OF 0EATI1, WHICH f:O~MS THE BA.S!$ OF lHE ClA1M. IF OTHER rHAN ClAIMANT, STATE lHE NAME
OF THE !NJURED PERSON OR UECEOENT.
Severe emotional trauma to A

d W tK
N
, A de
N
caused by saparatlon and ongoing civil
violations by refusal to allow daughter and parents to communicate although no charges have aver been proven and former
restraining order was court ordered due to Social Worker "saying" that child did not want to see parent after Isolating a minor
questioning her ~t ~ Yl'l old and manipulating evidence to support ongoing billing for unnecoosary services.
1i.
WlTN.ES.S'E-8
NAME
ADDRESS (NURlber, Stre6l, Clty, S\.il!.a, and Zip Code)
Warren R. Hamillon, Esq
107 Arch Street Philadelphia, PA [ 261-2359481]
Theresa Cowan
86 Vance Avenue Sicklerville, NJ
Ernesllne Yancy
Meahsn Street, Philadelphia, PA

AMOUNT OF ClAIM (!oOOUate:)
12. (SM lhtilluclloos on rnVtlrt;a).
12b. PERSONAL INJV~Y
12a. PROPERlY DAMAGE
12c. WRONGFUl DEA.TH
100,000.000' oo
i2d. TOTAL (Fnilure los~dftmay C<lUS6

ftlrleltum of your rlghle),
100,000,000,
"0
I CERTlFYTH"I\TTHE AMOUNT Of CLAIM CO\'GR$ ONLY bAMAOI:.S ANP ltUlJR.IES CAUSED O'ITH~ INCIOI:Nf Aat:NEANI'J A\lftEETO ACCEPT SAID AMOUNT JN
FUU.. 8AT{3FACTIO~ Atm l"ltfAL3Ent.eW~Nf OF lHIS CLAIM,
i3a. srGNATURE OF CtAIMANT (Soo lnswcd~~ Gil mvaroa Bide}.
13b. PHONE NUMBER OF PERSON SIGNING fORM 14, OATE OF SfBNATURE
856.302.5264
CJ\111. PENALTv'fot{ ~fU::.SENTmQ
FRAUDUI.ENTClAIM
05/21/2013
CRIMINAL peNAlTY FOR PRESfNIING fRAUDULENT

GLAlM 0~ MAIQ~G FAlSf: STATEMENTS
Tha dalmanlls lfabls- lo lha UnUBd Slulnt Govemmcnt for a civil penalty of not lass !hall
Fll\e,lmprlsoorMnt. orbnlh. (Saa16 U.S. C. 287. 1001.)
$(1,QI)O sod Ml mtYe-lh1m $10,000, pftt!l 3 Iimas Lho <lll)OUtlt of tf~!189~ $\1&\s!ned
D)"ltm Govemmoi'lt, (see 31 u.s.c. ~'1.2~)-
Au:lhorued for l~l ReproducUou

Previous EdiUon Is no\ Usable.
95109
NSN 7040-i!0-1!04-4046
STANDARD FORM 95 (REV. 212007)

PRE::.SCR!BEO BY DEPT. OF JUSTICE
28CFR 1<1.2
Nc. 48'0
Jun. 14. 2013 !0:59AM
P. 3
llf5URANCE COVI!RAOE
In order !hal wl::li'~tJ\fon cftliMs may no ildjlldlct~ted, It ls essen~! lhallhe dlllm1lnt pro.VI<Ie.lho foi!(IV<Ing lnflllmatlon regarding llia lnwrBtloo-covarana of!ha vahlda or properly.
15. Do yr.u carry $ctiQeflllnw~"e~noo1
0Yoo
If yw, give n(lma and addrosa orJ~UffilC.U company (NumOOr, Sln:ml. CitY, Slate-. and Zip GOda) i'IM pollcy numDM.
18]
No
NA
16. Ha'Va you ~lad a dBim wilh you~ insumnoo llWTiar In thlslllsbmoo, 1:md if so, Is i\_ full oovarage 0! deduc~l)le.'/
Yes
lZJ No
11.1/ {100udlbll). $\$16 amovnl.
NA
16, If a dalm haa baan filad with yoUr carrlar, wbal ~dl011
h~$
youf lr\::illrcr lai<M or p(I)(IOSt.d lO laM 'Mll1
r6!eren~
to yovr (!elm? (lliG n\'!00-W)ry lha\ Yf1J tt!t;:."el\llln \hii~Q f~,:~c{.$).
NA
1Y. Do yoo carry flUbllc i'!Bblli(y and pro)l'lrty damilga lnwranoo?
Yllll
IT ye.s, giYa hstne and addrass oi ln!itlfQhct:l Ol!'rtiii"(NliO)tJtr, 8treet, C!ty, .Slate, <md Zlp C<Jde). ~No
NA
INSTRUCTIONS
Claims prnted undor tho FodorI Tort Claims Act should bo submitted dlroolly to the "approprlete federal agency" Whose
employee(s) was Involved In the Incident. If the Incident Involves mor than one claimant, each claimant should oubmit a parate
cl~lm
fortn.
Complnto alllhnns- Jnsnrt Hte word NONE whero appHcable.
A CLAIM Sl-W.L BE DEE ME:[) TO HAVE BEEN PRESENTED WHEN A FEDERAL

DAMAGES IN A SliM CERTAIN FOR INJURY TO OR LOSS OF PROPERTY, PERSONAL
AGENCY RECEIVES rROM A CLJUMAN'l', HIS DUlY AUTtiORIZEO 1\QENT, OR lEGAL INJURY, OR DEATH ALlEGED TO HAVE OCCURRED BY REASON OF THe INCIDENT.
REPRESENYATIW, All fXecUYeo STANOARD fORM"' OR OTHER WRITTEN

NOnfiCI\TlON OF AN INGID~Nl, AGOOMPANli'!D BY ft ClAIM fOR MOJilff'(
Faflurll'! to complol1~ tiX&tuto this fonn or ~o "upply the reque.!llted materiA! w1lhln
two yuatsfrotn lh dil:ta Hm ohllm accroed may hlhdotyourt<lalfilftNal!d, A cliiitn
111 d'Qomad presan(ad when ll 111 n~cetvod by U1eapproprtate ag11ncy, not wh~t-nllls
m11lled.
lflnab"\lctfoo ts naOOttO In C001plallf1Qlh!s lonn, lhq ~encY !lsi!~ (lin Htllll #1 Qn lh~.t rev('lrae
slde may bo ctmtuctt:d. Ctlmpletc ~ulaUoos per1al{tloglo claims asserted under lha
FC'dc~<~l TorlClalma Act canbaflXJnd In TiUe2a, Coda ofFodornl ReglllaUofl.S. Part 14.
Many agancla.'! hnva publl$ed l\tlpplen11'-ntlng rogula11ooa. If moce lhan one agency Is
frwoJved, plea so slate eactl ;)g~ncy.
Tha claim maytm ~fled by a duly aulhorizod a.11ant cr olh11r!agal l'apl"Eilian{e!Na, pm'Ad'ad
av!danoo oo\Ja[ac(DI)' !o lha Government In &ubrnlltod wlU1 U1e claim aalabllahlniJ axprns.a
aulhorlty to ocl ftJr the cl~lmanl. A clslm pm&er~l!ld by an agent nr legal rEipra'ianU.tlva
must be preMnlt'd lnlho natno ullllc cl;JJmilnt. lflhe claim]$ $!gned by lhe ooelll Ql'
f(lgal r-epresoola!Iv.a.lt must choW \ha ll\Jo or lagal capaeity of lha parsnt~ slgnlng and bel
sccompSll!Bd ly etJdenoe of tua/h(lr oul.hQdty to prnaoo1 a dalrrton behalf of !he claim all\
3S <l-~11, (})(6CU!or, -adrnlntslrato(, p.1J'MI1, goardlM nr other represtlnlallvo.
If claknanl lnfenda (ll fila forbQlh ~1'8ooallnjury :11nd prOCIIIrly damaga, lho Brnoun\ for
cfltil mrl$lbe&.own In ltemnutnoori2 of this (Offi\,
THE ClAIM MUST BE PRESENTED TO lHE APPROPRIATE FEDERAL AOENOYV'lllHIN

~AFTER THE ClAIMACCRU~.
The emuunt d;llmM shoiAd bl!l tUb&lanUMed by compelen\ evldwce t!S (o\IOW:'l:
or
M til Sllppo/1 !he dslfll for personal ln!UI}' (If doalh, lha claimant ehoolr;l aubmlla
Wrin11n ttpotl by lho atlcl"ldlfW physldan, ~howlng \he nal\lre. ~nd e-xtenl oflh> Injury, Ule
natu/ll and axlehloflroalmanl. Uta dllgrtt>~ ul pt;lmlanBnldiS-.bllity, If any, IM pt6gnOt;h:,
~n(l !h~ perl()d I)/ hr;~3p~1lza\km, or 11\Capacl!ellan, sl;\adllngitank6d billa for medh::al.
I'IO!;pMI, or-nU1<>1 n"tpenses acwt:Uiy lnwrrOO.
(ll] In s11pp<lrl of clalma for damage lo propel'ty, Which hea boan N can be eoonomloo!ly
ttpa1red, !h(l cltJlm11ft1 s.hwld subml\ 11\le.at~liWo 1\flrnlzed algnl!d a1Bt1Utle!1t8 or astlrnatllll
by roUabla, dl!;lrttmmoltl tondlrns. or, n' !)ilyrttent l"ul!l boen ro~de, \he ll~l:ted sl!med
rsCtJipls e'Jidendng paymanl.
M lrisuppOrtofda~rnsfor dMlagalO properiyv..i1lth lS not c'!OOI)(lf111~yrep01mbl(l, nrh'

lho property !a lrn1l Dr de!!lroyed, lliB claimant shookl rubmil slalamanls Elli lo lha olfgi'fml
cost.oflhe. property, th& d~!e .or pUr~e, vnl;i lhawluo!l of !hnJY!)perty, boll1 Qa(Qr(l ~n(l
a ncr !ht~ i1cddot1! .such 5La(emeals shoold M by disinterested tQmpelent pe~.
prllfambty reputable dl!alem orotnclato famllhlf wilh Itt& type of ptop!ll-ty d-amagud, Of by
two or rJ\OI'e CQm~Jetit~Vt.l blcld'*-", ot11d ~houlr.l be C~trt!f!Gd 1:1!1 balnfliUaland 00/lar.t
(d) Fallumlospaulfyur;U\n cortalh will t~hdlltyourd"ltrt h1Vi:11ld ~hd trt<IY ro~UIIIh
forfellurn o( your rightn.
PRIVACY ACT NOTICE

lhT:o Nolk:a Jo; provided In acwrdancs wilh !ha Pfivllcy Acl. 5 U.S.C. 552B{Il}{3). and
coocem$ llle tnfefi'M;i.IQO fe;.J.UM\00 In the lell.ef ro-vtnloiJihl$ No~!M llJ attt~r.J-t~.
A. IHJt!Jot'ity: Tho re.:tus.slud ln(ormal:ion IS SOHC!led putsuanl to 001'1 ot ffiOf& of tho
following: 5 u.s.c_ 301, 28 u.s.c. 50-1 el seq . 2B u.s. c. 2671Bineq .. 28 G.F.R
P.aJl14,
8. Ptin~plll Putposr;: TM lnl(lt)Tlillk.ln rt'I'\Oetled [$\0 00 U$ed lrl 6V<llU~tJJ19 <:Mims.

C_ Roul/rlfJ U.ro; 8Ha lho Nol'icm ofSyPJsm&offteoord:o lot lli11 oQsh.tylowMm you nro
aubmit!lng thla lOOn for lhla lnfoonalion.
D. ffsd off.allure to Raapand: Dlsdoaura Ia vcluntiuy. HowaYflr, failwe to ./lupjjylha
rettuesle<l k'formatlon or to oo:et;ll\e titF;~ rorsn ma.y renr.IBI yoor dalm "Invalid.~
PAJ'ERWORK Rt:OUCTION ACT NOTJCE

This nolfoo fa !illlftl:t for lh~;~ purpwe ~f\ha PBparwork Raductioo Acl, 4---1 U.S.C. 3501. Public caporting burden lor lhls ccltedioo of in!onnatiOO\s oslimalod to tl'ltl~gc 0 hout5 pc!.r
f"EI>;pon~, lncludtfll) !flo \lfrw for re\'lew'ill[llllStrvctlons, $Wrclllng "Q;dstl~ ;;1:11!8 $lX!fOOS, gl!l.hwing 11nd IJ1Ilfnta)n1nglh~;~ data naaded, and r:ompleling nnd raviewing Uta oollaclion of
lnform-at1o11. Snhd oamm11nlli fCli)Brrling lhi6 burdcn qsl.i()13lU- or ony olllcr u1ipo;tl: of lhlf;; o:>llc~.iOI\ '(Jflflform;Jl!on, !nclodlfl!) suggesUoos for nxlutfpg lhl4 bvtden, llllheo DJreor, TOJ19:
BrGllch, AltenUon~ Pape!Willk Raduttlon Sl11ff, Civil Dlvl~lon, U.S. Or;~purtrnanl of Juijliw. Washlq~\011. DC 20530 otto lh11 Oifico ofMll.tr;~gt~-rMI'II ~lid Budget. [}(I not roi'1\J rompleled
fonn(s} to these \'lddre$(;es,
STANDARD FORM 95 R~V. (212007) BACK
PERSKIE FENDT
& CANNADAY, P.C.
-Attorneys at Law450 Tilton Road, Suite 260

Northt!eld, N] 08225
(609) 645-21 J l
FOJ<: (609) 484-0897
Toll Free: J (855) 313-4529
www.pandflaw.com
M. Daniel Perskie
Robert T. Fendt*
. Tara L. Cannaday*
Richard Kitrick
OfCounsd
Member NJ and PA Bar*'
1500 Walnut Street

Suite 1620
Philadelphia, PA 19102
(215) 569-0019
Fax: (215) 546-9559
Tax I.D. 22-3329845
March 26,2015
VIA REGULAR & CERTIFIED MAlL- R.R.R.
VIA REGULAR & CERTIFIED MAIL- R.R.R.
Attorney General's Office

State ofNew Jersey
Hughes Justice Complex
PO Box 080
Trenton, New Jersey 08625
Clerk- County of Cape May

7 N. Main StreetDN 109
PO Box 5000
Cape May Court House, NJ 08210
VIA REGULAR & CERTIFIED MAIL- R.R.R
VIA .REGULAR & CERTIFIED MAIL~ R.R.R.

Clerk- County of Cape May
Cape May County Administration Bldg.
4 Moore Road
Cape May Court House, NJ 0821 0
State of New Jersey

Division of Youth and Family Services
Cape May Local Office
Court House Commons
601 Route 9 South, Building 9
Cape May Cowthouse, NJ 08210
RE:
Claimant(s):
Date of Accident:
Place oflncident:
\i
VIA REGULAR & CERTIFIED MAIL- R.R.R.

Clerk- Middle Township
33 Mechanic Street
Cape May Court House, NJ 082 I 0
Richard Everett
February 18, 2015
Fall at alleyway adjacent to 601 Rte 9 S., Bldg. B, Cape May Courthouse, NJ
Dear Sir or Madam:

Please be advised that this office has been retained to represent Richard Everett with respect to the
above-captioned matter. Enclosed please find our Notice of Tort Claim.
Thank you for your attention in this matter and please feel free to contact my office should you have
ru1y questions, or should your need ru1ything futther at this time.
~er.tru~
.,
I '
<
TARAL CA
TLC/CAC
Enclosures
NOTICE OF TORT CLAJM

,
PLEASE TAKE NOTICE that a claim will be made pursuant to N.J.S.A. 59:1-l et seq. The
following information is submitted pursuant to N.J.S.A. 59:8-4. If there are specific forms designed
for the purpose of reporting information pursuant to the Act, please provide this office those forms.
1.
Name and post office address of Claimant(s):

Richard Everett
41 Lighthouse Drive
Brigantine, NJ 08203
2.
All notices are to be sent to:

Tara L. Cannaday, Esqui1e
Perskie Fendt & Cannaday, P.C.
450 Tilton Road, Suite 260
Northfield, New Jersey 08225
3.
Date and place of cause of action:

February 18, 2015; alleyway adjacent to 601 Route 9 South, Building B, Cape May
Courthouse, NJ
4.
Circumstances of occurrence or transaction giving rise to this claim:

Claimant Richard Everett was injured after slipping and falling due to a dangerous and
unsafe condition of the area at the aformentioned location.
5.
General description of injuries, damages or losses, known at present time:

Including bnt not limited to, injuries to the claimaut's low back, left hip, both knees and
both hands.
6.
Name(s) of public entity, employee(s) causing the injuries, damages or losses:

State of New Jersey, State of New Jersey- Department of Children and Families, Division
of Youth and Family Services, County of Cape May and Clerk- Middle Township.
7.
Amount presently Claimed:
To be determined.
Estimated amount of prospective injuries, damages, or losses are not know at this time. Basis of
computation of amount claimed: To be determined.
PERSIUE FENDT & CANNADAY, P.C.
:::~~::,':~:::IDe~"
SENT VIA REGULAR AND CERTIFIED MAIL, RR.R.
Nolire,
JUN/!2/20!5/FRI 12:09 PM
FAX No.
15- 3(c,8 I 5-:3GGS -o !) t(
P.002
rs~ 3(c{08 .~6::2
INITIAL NOTICE OF CLAjM FOR DAMAGES AGAINST THE STATE OF NEW JERSEY
Forward to: Tort and Contract Unit
Depaltment of the Treasury
PO Box620
Trenton, NJ 08625
Phone: 609-292-4347
1. CLAlMANTS:
RECEIVED
MAY 28 2015
DIVISION OF RISK MANAGEMENT
Amanda Martin Delfino Martin Baby A.M.
308 67'h Street, Apt 3

West New York, NJ 07093
2. IF NOTICES AND CORRESPONDENCE IN CONN'ECTlON WlTfl THIS CLAIM ARE TO BE
SENT TO A PERSON OTHER THAN CLAIMANT, COJVlPLETE ITEM #2:

Valerie Borek, Esq,
Attorney for Claimants
V. Borek Law Firm
2060 Chichester Ave.
Boothwyn, PA 19061
Ph: 484-321-3023
3. THE OCCURRENCE OR ACCIDENT WHICH GAVE lUSE TO Tl:US CLAIM

a. Dates and ti~nes: 02/27/2015-03/02/2015
b. Municil?ality: North Bergen
Exact Location: Palisades Medical Center. 7600 River Road. North Bergen, NJ 07047
c. Describe How Accident or Occur:tence Happened: Please See Below.
d. Name and Address of State Agency or Agencies that You Claim Caused Damage
i. North Bergen Police Department, 4233 John F Kennedy Blvd West, North Bergen NJ
07047
ii. Division of Child Protection and Permanency, Gateway Plaza 4'h floor, 1 Harmon
Meadow Blvd, Seacaucus, NJ 07094
Names of State Employees Whom You Clniin Were At Fault
iii. Two North Bergen police officers, names unknown, dispatched to Palisades medical
center on 2/27/2015 and 2/28/2015, both Hispanic. One officer was shorter and darker
skinned, the other was bald, tall, husky and light skinned and identified himself as a
paramedic as well as police officer.
iv. S\1W,ll Crespo, DCPP
v .. Au unidentified DCPP worker, who arrived with S. Crespo on 2/28/2015. She was fair
skilJlled, blonde hair, heavy set Hispanic.
vi. Darlene Mandziak, DCPP
vii. Simone Coombs, DCPP
vm. Does 1-10 from DCPP involved in this incident.
e. Negligence or Wrongful Acts of State Agertcy and Einployees which Caused Damages:
Please See Below.
:f. Identification of Witnesses:
JUN/12/2015/FRI 12:10 PM
FAX No.
P. 003
i JoAnne Olivieri, 23 66'h St., Apt l, West New York, N'J 07093
ii. Aaron Olivieri, 23 66'h St., Apt 1, West New York, NJ 07093
iii. Heather Taveras & Raphael Vicioso, 3150 Rochambeau Ave., Apt 4 Bronx NY 10467
iv. Farah Diaz Tello, National Advocates for Pregnant Women, 875 6' 11 Ave., Suite 1807,
New York, NY 10001
v. Hoboken University Medical Center, Willow Ave., Hoboken NJ
'Vi. Hackensack Medical Center, 3 0 Prospect Ave., Hackensack, NJ 07 60 l
vii. Dr. Rodrigo Castillo, 5801 Broadway, West New York, NJ 07093
viii. Everyone working in Palisades Medical Center from evening of2/27/2015 through
afternoon of 3/2/2015, especially in Labor & Delivery, and Emergency Department,
security staff, hospital administration, and doctors and nurses listed below in 4f.
g. Names of all Police Officers and Departments who investigated this1ncident:
i. North Bergen Officers Jorge Raposo and Gillian
ii. Two officers dispatched to Palisades on evening of2/27/2015 due to calls by claimauts,
one of whom was Hispanic and returned on 2/28/2015 at the request ofDCPP to
claimant's knowledge.
iii. North Bergen County Prosecutor's office, name unknown, contacted 2/28/15
iv. Hudson County Sheriffs Department, name unknown, contacted by phone 2/27/15
v. Hudson County Police Department, name unknown, contacted by phone 2/27/15
4. Claim for Damages;

a. Personal Injury
b. Property :Oamage
c. Othel'-
./
D
./
Please See Below.
If You Claim Personal Injury
d. :Oescribe lnjuries: Please See Below.

e. :Oo You Claim Permanent :oisabllity Resulting from this lnury'! No.
f. Hospital, :Ooctor or Practitioner Rendering Treatment, Exam or Diagnostic Services:
All of the following health care practirioners were working at Palisades Medical Center, 7600
River Road, North Bergen, N1 07047 at some time during the three days of this incident.
1. Dr. Artur Gosturani, Palisades Women's Group Clinic
n. Dr. David Fayngersh, 2/27/15
iii. Asian male nurse working in ER evening of2/27/2015
iv. Hispanic female nurse working in ER evening of2/27 /2015
v. Caroline N. Ward, supervisor working in ER evening of2/27/2015
VI. Second nurse, possibly Hispanic, working ER .evening of 2/27/2015
vu. Nurse, African American, name possibly Christine, who appeared to relieve nurse
supervisor Ward after her shift ended on 2/28/15.
viii. Unknown doctor, tall and older with a beard, claiming he was in charge of the ER from
2/27/15-2/28/15.
ix. Unknown doctor in ER on 2/28/15, Cuban, stated he was a pediatrician
x. Unknown doctor accompanying the Cuban doctor
XI. Unknown nurse accompanying the above two doctors.
xu. Dr. Robert Schaefer, presumed to have administered Pitocin against Mrs . .Martin's will
xiii. Male nurse working with Dr. Robert Schaefer on 2/28/15, administered anesthesia against
Mrs. Martin's wilL
xiv. Unidentified Asian female nurse 2/28/15, removed catheter
xv. Dr. Frank Santos, psychologist 2/28/15
XVI. Unidentified Asian, short, heavy nurse 3/l/20 15
xvii. Nurse Cheryl Roosten, spoke with claimants 3/1!15.
xviii. Dr. Dusan Petisic, spoke with claimants 3/2/15
JUN/12/2015/FRI 12:10 PM
FAX No.
P. 004
Any and all billing for services at this time are unknown an.d will be forwarded upon
receipt.
g. Wage loss-None claimed.
5. No P1operty Dan1age is being Claimed.
6. :No claims have been made against any other parties.
7. Losses or Expenses Covered by Any Policy oflnsurance: United Health Care Community :Plan, PO
Box 200089, Newark, NJ 07102
8. No Agreements have been made to receive any money from any one for damages claimed herein.
9. l>ocuments: All documents are being acquired and will be forwarded promptly upon receipt.
lO.lnformatioli. about the lncident;
Claimants were wrongfully detained at Palisades Medical Center in North Bergen New Jersey from
approximately 7:30PM February 2]. 2015 tjJrough al2J?roxilnately 3:30PM March 2. 2015. Over the course of
approximately three days, the above named individuals, agencies, and corporations acted in concert to deprive
Claimants of their constitutional rights, and committed tortious acts including, but not limited to false
imprisomnent, intentional and negligent infliction of emotional distress, interference with parental relations, as
well as violations of state and federal civil rights. Citing nothing other than the enoneous assertion that it is
i
to ive birth at home, DCPP employees and North Bergen police ass1sted staff at Palisades Medical
Center in depriving laimants of theit freedom and their privacy.
Ms. Martin gave birth to baby A.M. at home on February 27,2015. She had prenatal care throughout her
pregnancy with Dr. Artur Gosturani, a gynecologist at Palisades Women's Group Clinic. After her baby was
born at approximately 3:30PM on February 27,2015, Ms. Martin called Dr. Gosturani to notify him that
everyone was healthy, and to schedule a check-up. The d82#fnsisted she come in to Palisades Medical Center
immediately, and that he would simply check her ancf'the baby"and let'them go.
'~
---when claimants arrived at Pali"sa:aestVI:edical Center around 7:30 PM,'they were met by Dr. Gosturani
and Dr. David Fayngersh. The doctors asserted that their actions in having their baby at home were illegal and
DCPP had been notified. The Clajmants notified J4em and staff that they no longer consented to any
ex~n or tr..s;atmenJ, but they were forbidden from leaving the hospital by hospital staff and security. Dr.
Gosturani placed hands on Mr. Martin, and Nurse Ward grabbed Mrs. Martin and said "l wouldn't do that."
They were informed that if they left, the police would be called and send to their home.
Tbe ~I staff insisted ,Mom and Baby consent to meclical examination, and Claimants refused. The
only reason given was that they illegally gave birth ~t home. It is not illegal to give birth at horne. There was no
emergency. Ms. Mmtin called North Bergen :Police tp .explain she.was Q.eing wrongfully detained. 'J'Jlo o;tpcers
were dispatche and she was_____,_
told nothing could be done and she must simply wait for DCPP to arrive. The
officers d not 1dentify themselves, but were both Hispanic.
Mrs. Martin next called DCPP, who confirmed the hospital had called, and said they would send
someone ou~he early momrng of February 28, 2015,lJC'PFWorker Susan Crespo arrlved Wttli a blonde
Hispru;i'Zwoman also employed by DCPP. They stated they were "unfamiliar with the laws" surrounding birth
but that the hospital said it was illegal so they were not :fi:ee to go. DCPP and hospital staff continued to harass
Claimants and ~~th police action ()! remove.-1 of chil$]ren, in order to coerce them to sub~it'to mealc'al
exammatwns. Mrs. Martin reached out to both Hoboken Medical Center and Hackensack Medical Center to
transfer fci'r any necessary examinations, but Palisades Medical Center staff and doctors refused to effectuate a
transfer, or to allow Claimants to transfer themselves. Tbey were barred from leaving by security, staff, DCPP
employees and North Bergen police.
Around 8:00AM on February 28,2014, Claimants were also prevented from leaving to attend a
scheduled appoiuttnent with pecliatrician Dr. Rodrigo Castillo by the blonde Hispanic DCPP worker. She
threatened if they left she would call the police. The Martins informed her they had been trying to call the
police, but they wouldn't come. The DCPP worker left the room and then came bade shortly after with one of
the same Hispanic police officers that had beeu dispatched the night before, previously at the request of the
Martins. This time he was dispatched at the request ofDCPP.
The officer informed the Martins "You're not going anywhere; You're under arrest." They were not
allowed to leave. Claimants called North Bergen Police Department with their cell phone and was told by a
--
JUN/12/2015/FRI 12:10 PM
'
'
FAX No.
P. 005
dispatcher there was no warrant for their aJ.Test and that he would contact a supervisor and get back to them. In
the interim, a second officer anived, a light skinned Hispanic officer, who took the cell phones from the
Claimants, stating "Prisoners can't make phone calls." He further stated they were lucky to not be in handcuffs,
and the only reason he didn't do it was "as a cou1tesy." The officers stood at 1he doorway to the room,
preventing any escape. Officers provided no warrant, did not read any Miranda Rights, and prevented Claimants
the ability to reach out to legal counsel by taking their phones, barring them in the room and denying Mrs.
Martin's mother access to the family.
Subsequently, a Cuban doctor who stated he was a pediatrician, along with another doctor and nurse
came into the room with the two DCPl:' workers, .the light skinned Hispanic officer. They informed the
Claimants that if they did not consent to medical examination ofMfs. Martin and Baby A.M. then Mrs. Mmtin
would be jailed a!ld the f=ily'$ children taken away. The officer stated "You're under arrest for having the
baby at home, that's child endaJJgerment, and you're going to Kearny. My second job is a paramedic a!ld you
just don't do things like that."
The Claimants continued to refuse, and the parties eventually left the room. After some time, Officers
Raposo and Gillian walked in and were informed by Mr. Martin what was going on. 1be hospital staff ordered
Mrs. Martin and the baby to be admitted.
Baby AM had arrived with placenta still attached, in conformity with a Lotus birth. The Martins believe
in Lotus birth as part of their spiritual practices and belief system. The baby was taken to a separate room. The
Claimants had been informed this would simply be aJl exaJllination, but instead hospital staff proceeded to cut
the Cord and discmd the placenta. They admiilistered a VitaJllin K shot, and a Hep B vaccine and did blood
work. The Martins were not consulted about aJJY of this, nor would they have consented if given the chaJJCe. In
fact, they had explicitly refused any treatment at all from anyone at Palisades Medical Center. Finding out the
cord had been cut and placenta destroyed was especially painful for the fmnily.
Mrs. Mmtin was taken to an exaJllination room a!ld told to place her legs in stinups by Dr. Robert
Schaefer. His exaJllination was painful and when she told him he was hurting her he refused to be gentler and
yelled at her to cooperate. She continued to protest and was told "Since you are not cooperating I aJl1 going to
have to put you down." Arnale nurse then injected her with something unknown and put an oxygen mask over
her face, against her protests. When she awoke she was alone aJJd discovered a pain between her legs a!ld a
catl;leter. After pleading with aJJ Asian nurse to remove it four times, 1he nurse finally did, but told her she could
not see her baby because she had just woken up from anesthesia.
While this was going on, Mr. Martin was able to contact a prosecutor with 1he assista!lce of Officer
Rllposo, who had returned the cell phones. The prosecutor heard what was going on and said there would not be
any charges. The officers left the hospital.
Mrs. Mmtin was informed that while she was unwillingly under anesthesia, unknown persons at the
hospital administered Pitocin, which induces contractions. Mrs. Martin had experienced a very healthy birth at
home approxixnately 12 hours earlier, and did not'b:ave-a:uy-extraordinarypairruntil"she.. awoke-fromanesthesia
and had extremely painful contractions continuing fi:om 1he use of Pitocin hours after she had delivered her
baby and placenta.
On March 1, 2015 she was told by hospital staffshe'dbe going home that day with the approval of
DCPP. DCPl:' interviewed Md/or e:x:aJllined all parties individually, including Ms JoAnne Olivieri, Mrs. Martin's
mother, who had arrived at the hospitaL DCPl:' workers insisted 1hey would not allow 1he hospital to discharge
the Martins Until they consented to a horne evaluation. Under duress aJJd fatigued, a!ld against their wishes, the
couple gave permission to a home ex=ination. Mr. Martin and his brother Raphael Vicioso accompanied the
DCPP workers to the horne.
Throughout the day on March 1, 2015 the hospital continued to examine and do blood work on Baby
AM without the consent of the Claimants, and wi1hout explanation. On the same day, Mrs. Martin was told she
was not allowed to lay down to breast feed her son by an Asian sho1t nurse, and she threatened to remove the
baby if she saw it happening again. Another nurse, Cheryl Roosten spoke with ClaimaJJts and expressed
confusion as to why 1he fmnily had not been discharged since all the tests done on Baby AM were normal.
On March 2 the family continued to ask when 1hey could be discharged. Dr. Dusi'!Jl Perisic told the
parents they could go at noon but the baby couldnot. Eventually Darlene Madziak from DCPP spoke to the
parents and told them that in order to take the baby home they would have to consentto additional evaluations
JUN/12/2015/FRI 12:10 PM
FAX No.
P. 006
aft~r discharge----psychological and medical. She expressed dis belief that Mrs. Martin's name was in fact Martin
despite being shown identification.
Shortly after a nurse came in and simply removed the bracelet and alarm placed on Baby AM's
umbilical stump. The family was discharged around 3:30, and subsequently subjeCt to an open DCPP
investigation through approximately May 22, 2015.
The couple was coerced, threatened and harassed for three days straight by DCPP workers, police
officers, hospital staff and security. After having peaceful, safe, and healthy birth at home, Claimants were
subject to three days of torture by way of false detainment and deprivation of state and federal rights, which
enabled medical battery upon Mrs. Martin and Baby AM. Police and DCPP named above acted recklessly in
falsely detaining Claimants, subjecting them to unwanted and forced medical treatments against their wishes.
Mrs. Martin could not sleep the entire time she was kept at the hospital and not forcefully under anesthesia. It
was extremely stressful and traumatizing, which the family is still experiencing to this day. All medical
treatment and examination was done without consent.
All actors involved, including DCPP employees and the initial two officers that were dispatched to the
hospital could have easily verified that giving birth at home is not illegal. Detainment for refusal to consent to
unnecessary tnedical treatment js clearly a commonly known aspect of constitutional and fundamental privacy
and parenting rights. It is further a clear violation of the Fourth Amendment to hold persons against their will
for non-emergent medical treatment. The actions of all parties involved deprived Claimants of rights under New
Jersey and federal law. These actions should have been known to any reasonable person to be violations of
constitutional rights as well as battery due to lack of consent or consent obtained through coercion.
I HEREBY CERTIFY THAT TilE FOREGOING STATEMENTS MADE BY ME ARE TRUE. THAT THE .
ATTACHED STATEMENTS, BILLS, REPORTS AND DOCUMENTS ARE THE ONLY ONES KNOWN TO
ME TO BE IN EXISTENCE AT THIS TIME. I AM AWARE THAT IF ANY STATEMENT MADE HEREIN IS
WILLFULLY FALSE OR FRAUDULENT, THAT I AM SUBJECT TO PUNISHMENT PROIVDED BY LAW.
Date
Valerie
Bore~~
Claimants
P. 002
FAX No.
JUN/22/2015/MON 01:49PM
--ml
INITIAl NOTICE OF ClAIM FOR DAMAGES AGAINST THE STATE OF NEW JERSEY
FOWARD TO: DEPARTMENT OF THE TREASURY

20 WEST STATE STREET, PO BOX 6ZO
TRENTON, NEW JERSEY 08625-0620
/5--~17
RECBVED
MAY 2 9 2015
ET
DIVISION Of RISK MANAGEM N
PHONE: (609)292-4347
FORM MUST 61: Fllfb\VITI-JIN 90 DAYS OF THE ACCIDENT OR YOU MAY FORFEIT YOU_R RIGHT
BLlL\2>~&
NAME OF CLAIMANT
(MR. OR MRS.) CIRCLE ONE
,a:lo\ t~4
DATEO~BIR
STREET ADDRESS
STATE
CITY
'2/{~rQOF: ~ U!'/LQ.q
ZIP CODE
SOCIAL SECURITY NUMBtR
DAYTIME PHONE NUMBER
2. IF NOTICES AND CORRESPONDENCE IN CONNECTION WITH THIS CLAIM ARE TO B SENT TO A PERSON
OTHER THAN CLAIMANT, COMPLETE ITfM #Z
.-Mrm~~E\2~
o1A:- .
NAME OF PERSON
STREET ADDRESS
TELEPHON NUMBER
CITY
DATTORNEY
JS-
STATE
ZIP CODE
~HER~--------------------~-
(SPECIFY)
3A. CIRCUMSTANCES
REGA~DI~HE
OCCURRENCE OR ACCIDENT:
1:2kJfwDq ~a[:@rQ ~bj
___JlATE AN TIME
STATE VEHICLE DRIVER'S NAME
LOCATION (MILEPOST, NEAREST EXIT, CROSS STREET)
CITY
Oll
STATE
STATE PLATE# AND VEHICLE DESCRIPTION

3B. DESCRIB THE ACCIDENT OR OCCURRENCE: IFA DIAGRAM WILL ASSIST YOUR EXP-LANATION, USE A
SEPARATE SHEET AND ATTACH IT TO THIS FORM.
JUN/22/2015/MON 01:50PM
FAX No.
P. 003
3C. STATE THE NAME AND ADDRESS OF THE STArE AGENCY OR AGENCIES THAT YOUClAIM CAUSED
YOUR DAMAGE.
3131 Princeton Pike, BLDG 6
Lawrenceville, NJ 08638
Mercer County Hospital

750 Brunswick Avenue
Trenton, NJ 08638
STATE THE NAMES OF STATE EMPLOYEES WHOM YOU CLAIM WERE AT FAULT, INCULDING ANY
INFORMATION WHICH CAUSED YOUR DAMAGES
Lynn Spaeth" Caseworker Supervisor, D.C.P.P

Melanie Colon- Family Caseworker, b.C.P.P
Jay Byrne- Caseworker, D.C.P.P
Nina Crooks- Caseworker, Capital Health Mercer Hospital
State of New Jersey
3D. STATE THE NEGLIGENCE OR WRONGFUL ACTS OF THE STATE AGENCY AND STATE EMPLOYEES
WHICH CAUSED YOU DAMAGES.
I AM CLAIMING NEGLIGENCE, DISCRIMINATION AGAINST:
THE CASE WORKERS INVOLVED iN REMOVING MY CHILD
I AM CLAIMIMG CIVIL RIGHTS VIOLATION lSTr, 5TH AND 14TH AMENDMENT RIGHTS AGAINST:
THE STATE FOR NOT ALLOWING ME TO ENTER A PLEA OR EVIDENCE ON MY OWN BEHALP AND FOR
PLACING A DEFAULT JUDGMENT AGAINST ME (THE RIGHT TO DUE PROCESS)
At birth me and my child both tested negative for drugs APGAR was 9/9 Despite that my child was
removed without cause and placed in protective custody just 2 days after giving birth to her; this was
done without a warrant a; (law one brol<en) Pursuant of N.J.S.A_ 9;6-8.16, which empowers a
physician or hospital director to take custody without a court order of any child brought to him
for care and treatment who has suffered serious physical iniuries from what he interprets as
possible abuse. I was later found not guilty of abuse or neglect as found in Docket #(FN11000074"10), But my child as still removed.
Instead of placing the child with the child's aunt Catrina Griffin, who was in the hospital with
me when I gave birth; the state placed the child with an adoptive family, The state failed to
JUN/22/2015/MON 01:50PM
FAX No.
P. 004
follow;(Laws 2/3 Broken) The Foster Connection Act and the Adoption & Safe families Acts.
Catrina was asked by the caseworks at the hospital if she would take guardianship and she
stated she would DYFS took all of her information; but public records show that no follow up
from the agency Was ever conducted and my child was adopted out.
Subsequently a default judgment (Docket# FG"11"29-10) was placed against me citing rule 30
and 4~43-1. Given this, my child was placed t1p for adoption, and her name was changed to. I
was stripped of my civil and parental rights and was not allowed to defend the claims made
against me, present evidence or testimony when this default judgment was entered against me.
This is a violation of both the Foster Connection Act and the Adoption Safe Families Act.
Subsequently, the case was elevated to the Appellate court. The appellate court jttdges (The
Honorable Marianne Espinosa, Carmen Messanom, and John Kennedy) reviewed the decision
of the Honorable William Anklowitz and ruled that DYFS did not have the authority to remove
my daughter from me, and that a default judgment was granted without any evidence or
testimony allowed by me or on my behalf. The Appellate court agreed that the Honorable Jt!dge
William Anklowitz should not have accepted or entered a default judgment against me as
found in Docket #A4510-10TL and that I should at least get the opportunity to comply with the
guidelines as created by the court as ruled on 07/23/2012 by the Appellate court. However an
appeal (Docket# FG l12910) was filed, and despite witness testimony from several individuals
including one who was close to a case worker at DYFS, the state ruled that the appellate court
decision would be set aside, and the default judgment, as ruled by the Honorable Judge
William Anklowitz on 02/23/2014, would stand.
' JUN/22/2015/MON 01:50 PM
FAX No.
P. 005
4A. ClAIM FOR DAMAGES.

OTHER EXPLAIN: I AM REQUESTING $20,000,000.00 for violating my ~ivil
purposely breaking the law and adopting my child out without cause.
Contact Information;
Felicia Cain
3268 Frankford Avenue
Philadelphia, PA 19134
.Cell1: 2l5-908-6769
Cell2: Brother (215-435-3158)
Email address: Mscain1201@aol.com
& parental rights,
P. 007
FAX No.
JUN/22/20 15/MON 0I: 50 PM
fv"f:/../.1
-r::rli
INITIAL NOTICE OF CLAIM FOR OAMAGES AGAINST THE STATE OF NEW JERSEY
--d
/6
.
?
~f.{
RECEIVED

20 WEST STATE STREET, PO BOX 620MAY ?9 2015
TRENTON, NEW JERSEY 08625-0620
PHONE: {609} 292-4347
DNISION Of Rl&l\l'llAWIGEMENr
FORM MUST BE fllEO\VITHIN 90 DAYS OF THE ACCIDENT OR YOU MAY FORFEIT YOUR RIGHT
1.te\\60- CciD
NAME OF CLAIMANT
(MR. OR MRS.) CIRCL< ONE
STREET ADDRESS
\1. \o\ \ f!t.\

DATE OF BIRTH
CITY
DAYTIME PHONE NOMBER
SOCIAl SECURITY NUMBER
8-\~-<qc:j; ~ lQf/LoG\
STATE
ZIP CODE
2. IF NOTICES ANO CORRESPONDENCE IN CONNECTION WITH THIS CLAIM ARE TO BE SENT TO A PERSON
OTHER THAN ClAIMANT, COMPlETE ITEM #2.
n:r
1\\\:scet.~~RrnmQ
NAME OF PERSON
STREET ADDRESS'
---r2Jlili 1)
CITY
'TELEPHONE N MBER
DATTORNEY
o?:.U!
STATE
ZIP CODE
DriTHER__________________________
(SPECIFY)
3A. CIRCUMSTANCES REGARDING THE OCCURRENCE OR ACCIDENT:
s1 n \ro 40 .QrQ.W]: ~
____DATE AND. TIME
STATE VEHICLE DRIVER'S NAME
LOCATION (MILEPOST, NEAREST EXIT, CROSS STREET)
CITY
STATE
STATE PlATE# AND VEHICLE DESCRIPTION

38. DESCRIBE THE ACCIDENT OR OCCURRENCE: IF A DIAGRAM WILL ASSIST YOUR fXPlANATION, USE A
SEPARATE SHEET AND ATTACH IT TO THIS FORM.
D,c,f
FAX No.
JUN/22/2015/MON 01:50PM
P. 008
II
I
II
I
I
Plaintiff
I
I
Felicia Cain
''
I,,
3443 Ormes Street

Philadelphia,
P~ 19~.34
.I
Mscain12Dl@aol.c~!"
il
!!
I!
'!
215-908-6769 or 215-435-3158 .
:Oefenden.ts
State of New Jersey et al.
Department of Child Protection & Permancy
II
I~
Festus Agidi- Family Setvice Specialist
i1
I.
Ellen Blankstein- Family Service Specialist
11
Reim Nour- Family Setvlce Specialist

Maria Barbosa-Supervising Family Service Specialist
II
I.
Trenton Police Department
II
Detective Edgar Rios
"
I
l.
I
It Felicia Cain (Piaintiff)make the following accusations against the defendants listed above.
COMPLAINT- Factual Allegations
On the morning of March 17, 2013, my daughter was taken into State custody for
-not being properly supervisored after being placed there by law enforcement
while I was asleep after being held in custody for 7 hours.
My child had been kidnapped and I was severly beaten by my estranged

husband, but law enforcement failed to press char~es for the kidnapping, saying
that it's a 25 yr. sentence ..
Responding officers made slanderous allegations about rny soberity without
I,
FAX No.
JUN/22/2015/MON 01:50PM
P. 009
obtaining <:>Vidence which was available to them for over 7 hours.
I was denied visits wtth my child after her removal, causing her el<treme mental
distress which caused her to become catatonic.
My daughter was removed from her first foster home for abuse,and with injuries
to her spine that the Division will claim has been there since birth, but with no
records of such injuries before being taken into State custody.
The State claimed jurdistion of my child's removal all though she and I are/were
Pennsylvania residence. They made this decision without any further
investigation.
Laws violated
I hereby allege: Discrimination, Negligence, Violation of Plaintiff's Maternal Rights,
Violation of Plaintiff and plaintiff's child Civil and Constitutional Rights.
A.
Depriving plaintiff and plaitift's child the Right to life liberty, property and the right
guaranteed by State.
B. Depriving plaintiff and plaitiff's child, Civil Rights 42 U.S.C Section 1983, the right
to family integrality.
C. Disregarding the probability of plaintiff's child, suffering, emotional and mental
distress.
D. Knowingly and maliciously disregarding plaintiff's child best interest.
E. Knowingly and maliciously disregarding the Equal Protection Clause of the 14th
Amendment.
F. Inadequate foster care services, resulting in further emotional and physical
distress.
G. Knowingly and maliciously depriving Plaintiff of the Due Process Clause of the
Fourteenth Amendment.
Damages
II
Wherefore; Plaintiff asks for judgement against the defendants as follows:

_1._Plaintiff
request that all prior court rulings be reversed, and both of Plaintiff's
children returned.
!1_Piaintiff request relief in the amount of $80,000,000

.!!!,_Plaintiff request a Jury and enforcement of right to a swift trial.
I
I
JUN/22/2015/MON 01:50 PM
P. 010
FAX No.
As Dated:
May26, 2015
By:\
Respectful submitted
~b~Th~
\
Felicia Cain
Plaintiff Pro se'
Notary
CiTY OF PMILADELPif)A, PHILADELPHIA CNTV
.. of,ly Oomml.,lon Explru Dec 16.2016
~Ja fl.~~ c
;,..; . <:r'U:
,;;
FAX No.
JUN/22/2015/MON 01:50PM
s'. THE
P. 011
A~OUNTOF THE CLAIM$ 801 QOD I CfD
6. HAVE YOU MADE A CLAIM AGAINST ~YON ELSE FOR ANY OF THE LOSSES OR EXPENSES CLAIMED IN
THIS NOTICf?
DYES
1\ol'No
IF YES, SET FORTH THE NAME AND ADDRESS OF ALL PERSONS AND INSURANCE COMPANIES AGAINST
WHOM YOU HAVEMADE SUCH CLAIMS:
7. ARE ANY OF THE LOSSES OR EXPENswtLAIMEO HEREIN COVERED BY ANY POliCY OF INSURANCE?
OY~
~0
.
FOR EACH SUCH POLICY, STATE THE NAME AND ADDRESS OF THE INSURANCE COMPANY, POLICV NUMBER
AND 8ENFITSPAID OR PAYABLE.
8, HAVE YOU RECEIV0 OR AGREED TO RECEIVE ANY MONEY FROM ANYONE FOR THE DAMAGES CLAIMED
HEREIN?
DYES
DNO
IF YES, SET FORTH THE DETAIL OF SUCH AGREEMENT.
9. THE FOLLOWING ITEMS MUST BE SUBMITTED WITH THIS NOTICE:

(1) COPIES OF ITEMIZED BillS FOR EACH
M~DICAL
EXPENSE AND OTHER LOSSES AND EXPENSES CLAIMED.
(2) FULL COPIES OF All APPRAISALS AND ESTIMATES OF PROPERTY DAMAGE CLAIMED BY YOU.
(3) COPIES OF All WRITTEN REPORTS OF ALL EXPERT WITNESSES AND TREATING PHYSICIANS.
(4) A LETTER FROM YOUR EMPLOYER VERIFYING YOUR LOST WAGES. IF SELF-EMPLOYED, A STATEMENT
SHOWING THE CALCULATION OF YOUR CLAIMED LOST INCOME.
I HEREBY CERTIFY THAT THE FOREGOING STAT.EMENTS MADE BY ME ARE TRUE. THAT THE ATTACHED
STATEMENTS, BILLS, REPORTS ANDDOCUMENTS ARE THE ONLY ONES KNOWN TO ME TO BE IN EXISTENCE
AT THIS TIME. I AM AWARE THAT I~ ANY STATEMENT MADEHEREIN IS WILLFULLY FALSE OR FRAUDULENT,
THAT lAM SUBJECT TO PUNISHMENT PROVIDED BY LAW.
t!)?J.al~
DATE
&m Ufu CauD
CLAIMANT OR PERSON FILING ON BEHAlF OF CLAIMANT
TORT CLAIM NOTICE

' l~' ') .!':
., \. . ; i iA;'':
3 (v )6- /'>, . . .-\tj.{
t;J PI RRDf\) "-l tJ-~ T\ c;
1.
'~.._
li{f
:> ~v ll'.-1
f'- ...k.-
' ,.._.de.,.
Street Address
Name of Claimant
'Date of1Birfh
City
Social Security Number
Home Telephone Number
Telephone number at which you can be reached during the hours of9 a.m. to
5 p.m. _ _ _ _ _ _ _ _ _ _ _ _ _~
2. . H_it is requested that notic~s be sent
t:, a person other' t?an
c:ai~~nt, state:
<J bFF AlJ Vok A1. (5}-!J. d- ~ Jl), /Jf-J !{ t Pc.fiJ!-./

1
Name of Person
Mailing Address
L1J3 -091 -)LJJ-1

Telephone Number
rvJ DJ9Co
f!()f2iJJf7{)Ldl)l
City
J-'J--J ----r ~) n--'N.
State
Zip
./
Relationship to claimant _ _.,___:__.~::__..:.'~L::.:/.....:..'____:_ __..::::'--/~/_ _ _ _ _ _ __

The accident or occurrence:
3.
5- :/~J-l ~c:;
TO
Date
City or Town
-~~1-im_e__
/\) f.LL 1A((
Location
r.
N..).,
State
Des.clibe the accident or occurrence:
I\..
/:I
1 l
1\
~/
c. 0. P . l
LH AR. GL
1'U-- 0l F--\..:\
t./1 'iJ '
i t"J. \J
(- .r\
- ) !
I iC I{.J/
CJ L; _C
\1\
,_ U
/~
State the names and address of aU witnesses:

J
~A
"II j .11..
1 ,,,Jv,cJn
$ ifL.Ji....' '1
) f'.. ;'!':)---;J'
'\
.
/-\1
I ) ~)(,~)
.(
4. a)
b)
State the name and address of each State agency and each State employee
whom you claim caused your damages o:r injuries.
State the name and address of all other persons, companies, or governmental
Agencies whom you daim are responsible for your injuries or damages.
TJ~fr
5.
Briefly describe the injury, damages and losses incurred by you.
1 11i): ;::_,.... Li
j;_-
6.
.::
.~\ lf 1
- .1
State the amount claimed by you $
/1/)L"') r:.:. ,!z
II'
./
;c/Cc
'" I
'
/' \ : , }j
-.c 7\
U i L tz / .L....U
LJv'li'lJ ( .) LV
/l
'
State the basis of the calculation ofthis loss--------~----
I hereby certify that the foregoing statements made by me ate true. I am

aware that if any statement made herein is willfully false or fraudulel,lt, that I am
subject to punishment provided by law.
NOTICE OF TORT CLAIM PURSUANT TO NJSA 59:8-1 et seq.

1)
Claimant:
Silyne M Thomas
2)
-'
Notices:
Mark Law Firm, LLC

Jamison M Mark, Esq.
403 King George Road
Suite 201
Basking Ridge, N.J. 07920
3)
Basis of claim:
Assault
Battery
Intentional Infliction ofEmotional Distress
Negligent Infliction ofEmotional Distress
Vicarious Liability
State Created Danger
NJ Civil Rights Act
4)
The harm that occurred as a result of defendant's acts include:

Infliction ofEmotional Distress, Harassment & Hostile Work Environment, Loss of
Status, humiliations, anxiety, depression, loss ofpotential earnings, loss ofsocial
affection, loss of reputation, attorney's fees & Cost of litigation
Total Monetary Demand- $10,000,000
5)
Trial by jury. Yes.
6)
Defendant's names:
County ofHudson
Regina Caldwell
Remarkable Massi Youth Council
Philip Carrington
Kathy Baggett
*Bergen County
466 K!nderkamack Road
Oradell, New Jersey 07649
(201) 787-9406
*Essex County
40 Clinton Street
Su!te 301
Newark, New Jersey 07102
*Union County
2444 Morris Avenue
Un!on, New Jersey 07083
(973) 440-2311
(973)440. 2311
~By
appointment only
\VWW.NewJerseyAttorneys.com
essex County
One Passaic Avenue
Fairfield, NewJersey07004
(973)244-7944
;NITIAL NOTICE OF CLAIM FOR DAMAGES AGAINST THE STATE OF NEW JERSEY
20 WEST STATE STREET, PO BOX 620
TRENTON, NEW JERSEY 08625"0620
PHONE: {609) 292-4347
lOMiiiVN
OF kt<)" ,.;r.><AdEMENT
FORM MUST BE FILED\oVITHIN 90 DAYS OF THE ACCIDENT OR YOU MAY FORFEIT YOUR RIGHT
Joanne M. Shockley as
l. natural guardian of J
NAME OF CLAIMANT
~arent
and
S
(MR. OR MRS.} CIRCLE ONE
01/28/2000
414 W. Anna Street

------------~-------------
STREET ADDRESS
Cape May Court House, NJ
DATE OF BIRTH
CITY
08210
STATE
ZIP CODE
609-536-2993
DAYTIME PH.ONE NUMBER
2. IF NOTICES AND CORRESPONDENCE IN CONNECTION WITH THIS CLAIM ARI! TO BE SENT TO A PERSON
OTHER THAN CLAIMANT, COMPLETE ITEM #2.
Michael M. Shaen, Esquire

Best & Shaen, P.C.
5102 New Jersey Avenne
NAME OF PERSON
STREET ADDRESS
609-522-5252
Wildwood, NJ
TELEPHONE NUMBER
CITY
RELATIONSHIP TO ClAIMANT:
E!ATIORNEY
08260
STATE
ZIP CODE
DOTHER----------------------------~
(SPECIFY)
3A. CIRCUMSTANCES REGARDING THE OCCURRENCE OR ACCIDENT:
November 19, 2013 @ approx. 7:00p.m.

.
AND TIME
-- DATE
- - ... - ... - .. - ---
N/A
STAT': VEHICLE DRIVER'S NAME
Pineland Learning Center, Inc.

LOCATJON {MILEP.OST, N.EAREHEXIT, CROSS STREET)
520 N. Fourth St., Vineland, NJ

CITY
08360
STATE
N/A
STATE PLATE# AND VEHICLE DESCRIPTION
3B. DESCRIBETHE ACCIDENT OR OCCURRENCE: IF A DIAGRAM WILL ASSIST YOUR EXPLANATION, USE A
SEPARATE SHEET AND ATIACH IT TO THIS FORM.
Claimant was a student at the Pineland Learning Center, Inc.
His arm was broken
by Keith Bryant, a Teacher.
... ........ =
~=><
3G, 'ST.AT!i THE NAME AND ADDRESS OF THE STATE AGENCY OR AGENCIES THAT YOU CLAIM CAUSED YOUR
DAMAGE.
Department of Education
Department of Children and Families -Division of Child Protection and Permanency.
STATE THE NAMES OF STATE EMPLOYEES WHOM YOU CLAIM WERE AT FAULT, INCLUDING ANY
INFORMATION TH.l)TWILLASSIST IN INDENTIFYING AND LOCATING THEM.
To be supplied.
3D. STATE THE NEGLIGENCE OR WRONGFUL ACTS OF THE STATE AGENCY AND STATE EMPLOYEES WHICH
CAUSED YOUR DAMAGES .
Department of Edu.cation and Department of Children and Families failed to properly

license, inspect, investigate, maintain, control or supervise_ Pineland Learlling Center, Inc.
3E. STA:S THE NAME AND ADDRESS OF ALL WITNESSES TO THE ACCIDENT OR OCCURRENCE.
All parties.
3f. STATE THE NAMES OFJ\.Ll POUCEOFfiCERSAND POliCEtlEPARTMENT5-WHO INVESTIGATED THIS

ACCIDENT. PROVIDE POLICE REPORT CASE NUMBER, IF
. AVAILABLE.
Vineland Police Department Case No. 13 056901

See Police Report attached.
4A. CLAIM FOR DAMAGES (CHECK APPROPRIATE BLOCK):

lJPROPERTY DAMAGE
lJOTHER-EXPLAIN. _ _ _ _ _ _ _ _ _ __
4'8. IF YOU .CLAIM. PERSONAL INJURY:

(1) DESCRIBE YOUR INJURIES RESULTING FROM THIS ACCIDENT OR OCCURRENCE.
Acute displaced fracture of the right proximal humerus at the metaphyseal region
extending into the lateral aspect of the growth plate.
(2) DO YOU CLAIM PERMANENT DISABILITY RESULTING FROM THIS INJURY:
IDES
DNO
IF YES, DESCRIBE THE INJURIES BELIEVED TO BE PERMANENT.

See (1) above.
(3) FOR EACH fi.OSPITj)L, POCTOR OR OTHER PRACTITIONER RENDERING TREATMENT, EXAMINATION OR
DIAGNOSTIC SERVICES1 STATE'
NAME OF HOSPITAL,
OATES OF
AMOUNT OF
AMT. PAID OR PAYABLE
ADDRESS
DOCTOR OR OTHER
TREATMENT
CHARGE TO
BY OTHER SOURCE, I.E.
FACILITY
OR SERVICE
DATE
INSURANCE
~-~
--
See Medical Summary at ached.

-- '--,_
(4) IF YOU CLAIM LOSS OF WAGE OR INCOME AS A RESULT OF THE INJURY STATE:
... N/A
NAME OF EMPLOYER
ADDRESS OF EMPLOYER
YOUR OCCUPATION
RATE OF PAY
DATE OF ABSENCE FROM WORK
TOTAL LOSS WAGES TO DATE
IF STILL OUT, EXPECTED DATE OF RETURN
NOTE: IF YOUR CLAIMED LbSS OF INCOME ARISES FROM SELF-EMPLOYMENT OR OTHER THAN WAGE
'
ATTACH ACALCULATION SHOWING THE BASIS OF YOUR CALCULATION OF LOST INCOME.
(5) SET FORTH ANY AND ALL OTHER LOSSES OR DAMAGE CLAIMED BY YOU.
To be supplied.
4C.IF YOJ CLAIM PROPERTY DAMAGE;
(1) DESCRIBE THE PROPERTY DAMAGED.
N/A
(Z) THE PRESENT LOCATION AND TIME WHEN THE PROPERTY MAY BE INSPECTED.
[3} DATE PROPERTY ACQ.l,JIRED

:4) COST OF PROPERTY$
:s) VALUE OF PROPERTY AT TIME OF A C C I D E N T $ - - - - - - - - - ;6) DESCRIPTION OF DAMAGE.
7}HAS THE DAMAGE BEEN REPAIRED?
DYES
ONO
IF SO, BY WHOM, WHEN AND COST OF REPAIRS.
.. .............
~-.
8) ATTACH EACH ESTIMATE OF REPAIR COSTS TO THIS FORM.

9) SET FORTH IN DETAIL THE LOSS CLAIMED BY YOU FOR PROPERTY DAMAGE.
ID .. SET FORTH IN DETAIL ALL OTHER ITEMS OF LOSS OR DAMAGES CLAIMED BY YOU AND THE METHOD BY
WHICH YOU MADE THE CALCULATION..
5. THE AMOUNT OF THE. CLAIM$ _l_:_,O_O_O_:_,o_o_o_._ _ _ _ __
6. HAVi YOU MADE A CLAIM AGAINST ANYONE ELSE FOR ANY OF THE LOSSES OR EXPENSES CLAIMED IN .
THIS NOTICE?
UYES
ONO
IF YES, SET FORTH THE NAME AND ADDRESS OF ALL PERSONS AND INSURANCE COMPANIES AGAINST
WHOM YOU HAVEMADE SUCH CLAIMS: Pineland Learning Center, Inc.
7. ARE ANY OF THE LOSSES OR EXPENSES ClAIMED HEREIN COVERED BY ANY POLICY OF INSURANCE?
l(IYES
ONO
FOR EACH SUCH POLICY, STATE THE NAME AND ADDRESS OF THE INSURANCE COMPANY, POLICY NUMBER
AND BENEFITSPAIDOR PAYABLE.
Horizon CCN7770001799456202
8. HAVE YOU RECEIVED OR AGREED TO RECEIVE ANY MONEY FROM ANYONE FOR THE DAMAGES ClAIMED
DYES
KJNO
. . ..
HERWl?
IF YES, SET FORTH THE DETAIL. OF SUCH AGREEMENT.
9. THE FCJLLOWING ITEMS MUST BE SUBMITIED WITH THIS ]IJOTICE:

(1) COPIES OF ITEMIZED BILLS FOR EACH
M~DICAL
EXPENSE AND OTHER LOSSES AND EXPENSES CLAIMED,
(2) FULL COPIES OF ALL APP_BAISALS AND ESTIMATES OF PROPERH DAMAGE CLAIMED BY YOU.
(3) COPIES OF ALL WRITfEN REPORTS OF ALL EXPERT WITNESSES AND TREATING PHYSICIANS.
(4) A LETI ER FROM YOUR EMPLOYER VERIFYING YOUR LOST WAGES. IF SELF-EMPLOYED, A STATEMENT
SHOWiNG THE CALCULATION OF YOUR CLAIMED LOST INCOME.
I HEREBY CERTIFY THAT THE FOREGOING STATEMENTS MADE BY ME ARE TRUE, THAT THE ATIACHED
STATEMENTS, BILLS, REPORTS ANDDOCUMENTS ARE THE ONLY ONES KNOWN TO ME TO BE IN EXISTENCE
AT THIS T:11E. I AM AWARE THAT IF ANY STATEMENT MADEHEREIN IS WILLFULL
LSE OR FRAUDULENT,
THAT I AH SUBJECT TO PUNISHMENT PROVIDED
(JJl(}\lJ
DATE
C MANT OR PERSON FILING ON BEHALF OF LAIMANT

Jolmne M. Shockley as parent and natur~uardian
of J
S
.
INITIAL NOTICE OF CLAIM FOR DAMAGES AGAINST THE STATE OF NEW JERSEY
!
FOWARD TO:
Toln AND CONTRACT UNIT
DEPARTM~NTOFTHETREASURY,BUREAUOFRISKMGMT.
REC"
1\'f-E":f.~_ _ _.,_
J'l
ul 14 2014
ffi~~o
IR~NTON,NEWJERSEY08625
. PH9NE: (609) 29H347
t:_.'.-.--
01\liSION OF RISK MANAGEMENT
FORM MUST BE FILED \VI' THIN 90 DAYS OF THE ACCIDENT OR YOU MAY FORFEIT YOUR RIGHT
'
'
'
1. CLAIMANT:
K
-Ga
LAST NAME
MIDDLE
FIRST
ol r c;oursey roaq
Oreland, PA 190713
ADDRESS
. , MAILJNG ADDRESS IF OTHER THAN ADDRESS
(201) 420-1911
8/3/02
Telephone
DATE OF BIRTH
2. IF NOTICES AND CORRESPONDENCE I~ CONNECTION WITH THIS CLAIM.ARE TO BE SENT TO A PERSON OTHER THAN
CLAIMANT, COMPLETE ITEM #2.
i
.
.
.
1201 Hudson Street
Suite 230
Hoboken, NJ 07030
The Mullen Law Firm

NAME
MAILING ADDRESS
same as mailing address'
'
;
201-420-1911
ADDRESS
RELATIONSHIPTOCLAIMANT:
TELEPHONE
'
ATTORNEYATLAW ~ OR
J
3. CIRCUMSTANCES REGARDING THE
'
EXPLAIN RELATIONSHIP
O~CURRENCE OR ACCIDENT:
09/2009-05/2011
diverse times
DATE
;TIME
South Logan Avenue, Trenton, New Jersey
EXACT LOCATION OF THE OCCURRENCE

4. DESCRIBE THE ACCIDENT OR OCCURE~CE.
roug
e neg rgen , wr u an reo ess .al ure o
aeo
ew ersey an.
rvrson o
ou
an
am1 y ervtces o proper y
conduct an inv,!lstigation and/or to provide ~ervices to the minor, K

K
-G
such minor was exposed to continued
abuse, neglect, assault and other criminal <!nd wrongful conduct, resulting in ]ler perm<!nent physical and psycholog!cal damage.
5. STATE THE ,NAME AND ADDRESS OF ALL WlrNESSES TO THE ABOVE ACCIDENT OR OCCURRENCE.
'
.._
'
.
6. STATE THE NAMES AND ADDRESSES OF EAqH STATE AGENCY OR AGENCIES AND EACH STATE EMPLOYEE WHOM YOU CLAIM CAUSED YOUR
DAMAGES OR INJURIES.
I
.
I
I
?.STATE THE NAME AND ADDRESS OFALLQTHER PERSONS, COMPANIES OR GoVERNMENTAL AGENCIES WHICH YOU CLAIM ARE RESPONSIBLE FOR
YOUR INJURIES OR DAMAGES.
' LOSSES INCURRED BY YOU.

8. BRIEFLY (JESCRI~E THE INJURIES, DAMAGES ~ND
e mmor,
was permanen y an serr.ous y lnJU(e an a, use . y er 10 og1ca mo .er an

er mo er s l en
bqyfriend and unknown others. These inju\ies include roee burns and injuries, starvation and ma~nourishment, neglect and repeated and
continued abuse.
. 1
,
.
.
The physical injuries to K

.G
-K
have required surgery to skin graft open woundsand sores on her arms caused by
rope injuries. The minor will conthiue to require surgical and other medical care as she grows. The physical wounds are permanent and
cannot be repaired by skin graft or surgery.!
,
'
.
In addition, K
will require ongoing ~nd lifelong counseling and psychological care for psychological and psychic injuries she
received from her biological mother and astociate., as well as unknown others. :
9. THE AMOUNT OF T!iE ClAIM.
$50,~00,000.00
--~,----------------GIVE THE BASIS FOR THE CALCULATION oF TH~ ABOVE DAMAGES:

e m1nor c a1man WI require a 1e 1me o jme 1ca an psyc o og1ca rea men
'3 3L{ '-'/ -' !+K

LieblingM~l~W}ffk~
j3 ~
4Dil-f' /?ej)o ~ 1e3 612 7~'~rc
Scott D. Liebling, Esquil t*

Adam S. Malamut, Esquire t
Robert C. Wolf, Esquire t
Keith J. Genres, Esquire 'I*
t Member of the NJ Bar
/36'13 6 l'fdc._
SJ,_k;(,ttf T:.Jlr.A. 1--. I )JJ',;.(/6- I 36 931 ;(JC
"'- 0 uf L,ItA-TE
11
~\ ~/' ~:
1939 Rome 70 East
Suite 220
Cherry Hill NJ 08003
ph 856 424 1808

fX 856 424 2032
web W\VW.LMLawN].com
OF COUNSEL
Paul W. Sonsrein, Esquire
RECEIVED
JUL i 5 2013
* Member of the PA Bar
DiViSION OF Ri!.iK MANAGEMENT June 24, 2013

Via Certified Mail-RRR and Regular Mail
7007 ono oom 8616 6477
Office of the Attorney Ueneral
State ofNew Jersey
Hughes Justice. Complc<
25 W. Market Street, P.O. r;ox 080
Trenton, NJ 08625
Attn: Dcp<wtment of Treasury- Bureau of Risk Management
RE:
Andre Redd and Shailae Tibbs individually and

on behalf of minor claimant, A.R.
Dear Sir/Madam:
Please bt: advised that this office represents Andre Redd and Sbai1ae Tibbs, individually
and on behalf of minor claimant, A.R. In accordance with N.J.S.A. 59:1-1 et seq.,Andre Redd
and Shailae Tibbs hereby offer the to !lowing Tort Claims Notice:
1.
CLAIMANT INFORMATION:
Name:
, \dclress:
2.
Andre Redd and Shailae Tibbs, individually and on behalf of minor

claimant, A.R.
424 Cherry Street
Camden, NJ 08103
POST OFFICE ADDRESS TO WHICH NOTICES SHOULD BE SENT:
,\damS. Malamut, Esqt;ire

Liebling & Malamut, LLC
1939 Route 70 East, Suite 220
Cherry Hill, New Jersey 08003
( 856) 42.:1-1808
( 856) 42.:1-2032 (t)
3.
CIRCU'viSTANCES REGARDING THE INCIDENT:

Date of! ncidcnt:
4.
May 16,2013
DESCRlPTION OF INCIDENT:
Minor claimant A.R. was enrolled in the Head Start program at Center for Family
Services located at 500 Pine Street in Camden, NJ. Upon information and reasonable belief, on
May 16,2013, approximately 2:00P.M., the minor claimant, A.R., was released from the Center
for Family Senices, by an individual reasonably believed to be an employee of Center for Family
Services, Shancc Monk. to an unkno\.Vn/rmnamed individual, reasonably believed to be a driver
employed by the New Jersey Department of Youth and Family Services (DYFS). The driver, in
turn, took minor claimant, AR., to an unknown physician's office, wherein, she underwent an
examination, and then brought to an nnknown individual's residence. After which, she was
returned to the Center f(Jr Family Services. Upon information and reasonable belief, there was
no procedure or protocol followed or required by the Center for Family Services to allow minor
claimant AR., to be released tiom the premises. In addition, neither the Center for Family
Services nor DYFS had Andre Redd and/or Shailae Tibbs' pennission and/or consent to
take/release minor claimant tiom the premises.
5.
PUBLIC ENTITY: State ofNew Jersey

o;vision of Youth and Family Services
Camden East Local Office
4 Echelon Plaza, 2"d Floor
20 I Laurel Road
Voorhees, NJ 08043
6.
CLAIMS FOR DAMAGES: To be determined
The amount claimed as of this elate cannot be ascertained since the damages are
being presently incurred and \Viii continue for some time in the future. In accordance with this
Statute, this int;mnation will be supplemented throughout the pendency of this claim.
If there are any other forms which you desire that we complete under Title 59:8-6, kindly
advise and we will be happy to comply.
I certifY that the foregoing statements made by me are true. I am aware that if any of the
foi"egoing statements made by me are willfully false or fraudulent, I am subject to punislunent as
provided by law.
Sincerely,
ASM:cg

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2700 PACIFIC AvENUE

WILDWOOD, NEW jERSEY o!h6o

FAX 609 522 4927

December 29, 2014

"CERTIFIED CRIMINAl TRIAl AlTORNEY

VIA CERTIFIED MAIL #7011 2970 0000 1776 8367

t ADMITTED TO PRACTICE IN PENNSYLVANIA AND

NOTICE OF TORT CLAIM

Josephine Raimondo on behalf of minors C.R., N.R., and

Amount presently claimed:

Estimated amount of prospective injuries, damages or losses:

Basis of computation of amount claimed:

BARRY, CORRADO & GRASSl, P.C.

Dated: December 29, 2014

Stathis & Leonardis

Phone: (732) 494-0600

File No: 14-3180NJL

February 19, 2015

Sent via regular mail and cmjrrr

Divison of Child Protection & Permanency

Tort Claims Unit

Tort Claims Unit

Ladies & Gentlemen:

NOTICE OF CLAIM PURSUANT TO TITLE 59

Pursuant to N.J.S.A.59: 8-4, the within claim is presented:

Via Certified Mail, Return Receipt Requested and

State of New Jersey

NAME AND ADDRESS OF CLAIMANT

The post office address to which the person presenting the

DATE PLACE AND & OTHER CIRCUMSTANCES OF

On or about April 8, 2011, claimant was placed by the public entities

It is also contended that the locations of claimant's placements were an

GENERAL DESCRIPTION OF INJURIES DAMAGE OR LOSS

The claimant sustained multiple injuries and trauma. The claimant

THE AMOUNT CLAIMED TO DATE IS:

Attorneys for Claimant:

Dated: February 19, 2015

Mar. 19. 2015 12:46PM

Monmouth North litigation

PHONE: (609} 292-4<147 -~

Be \- J\~ \\ -- -- -.. -.. 33:BCL~~\derrutwtt~----

NAME 01' CLAIMANT _: 1\lR OR MRS.) cm~Le ONE

. \Seotwta~c t'1~ 1 \q]~

DAYTIME PHONE NUMBER

sTA'TE VEHJCtEDRiVER'S NAME

lOCATiON (MILE~OST, NEARESTEXIT, CROSS STREET)

... 3fl . OESCRI&E

,Jke Bssodoerl C'."""'.a,;=:;e..,...-:t~~-~~~~---'

2015-12:46PM--:-Monmouth North litigation

INITIAl NOTICE OF ClAIM FoR~OAMAGES AGAiNST T'HE STATE OF NEW JERSEY

3A: CIRCUMSTANCES REGARDING THE OCC~RRENCE OR ACCIDENT:

STAlE Vl'HIClE DRIVER'S NAME.

.. STATE' PLATE# AND VI'HlCLE DESCRIPTION

;See 8ssoG\ared CC4\e *

Mar. 19. 2015 !2:46PM

Monmouth North Litigation

)N~ORMATION'!HA'r Wltt:ASSIST 1f'fiNDENTlFVINt:rAND10CATil'lG'TREfvf

CAUSED YOUR DAMAGES.

ffildclkTh\1tL]'f) \L\QqJ.\- DDIQ~

4A.. ~I.AIM FOR DAMAGES (CHECK APPROPRIATE !!lOCK}:

Mar. 19. 2015.12:46PM

Monmouth North Litigation

Mar. 19. 2015 12:47PM

Monmouth North Litigation

,Jke Bssodoerl C'."""'.a,;=:;e..,...-:t-~~---'