JACOBS & BARBONE,P.A. EDWHN}.JACORS TR ‘A PROFESSIONAL CORPORATION ‘ecohalaccabarbone law ne ATTORNEYS ATLAW. [eartoneOjacobabaonelawe 1125 PACIFIC AVENUE “ATLANTIC CITY, NEW JERSEY 09401 "PHONE: (608) 348.1125, BAX: (69) 348-5774 ‘WEBSITE: December 16, 2019 Via certified mail, r.rr., regular mail Anthony J. Coppola, Jr. Galloway Township Municipal Government 300 East Jimmie Leeds Road Galloway, New Jersey 08205 RE; Tort Claim of Donald Purdy Our File No. 16,665. Dear Mr. Coppola: Please be advised this office represents Donald Purdy in a potential civil lawsuit to be filed in the Superior Court of New Jersey, Law Division, Civil Part, Atlantic County or in the Federal District Court. This letter is being forwarded to you in accordance with the terms of N. 59:8-4 and N.J.S.A. 59:8-7 and is intended to advise you of my client's claims against the Township of Galloway, Councilman Jim Gorman, and other municipal members and administrators. | offer the following information with respect to that claim. 1. My client’s full name and address is as follows: Donald Purdy 805 Third Avenue, Galloway, New Jersey 08205 2. Notices regarding this claim are to be sent to me at the following address: Edwin J. Jacobs, Esquire Jacobs & Barbone, P.A. 1125 Pacific Avenue Atlantic City, NJ 08401 3. This claim arises from libelous statements published by Councilman Jim Gorman in two letters sent to the Galloway community regarding the November 5, 2019 election. Those letters falsely alleged that ex-mayor Purdyreceived political payouts from the Galloway Planning Board as well as collected tens of thousands of dollars under a “lucrative towing contract” with the Township. 4, My client has suffered injuries and damages to his good name and reputation, standing in the community, personal humiliation, mental anguish and business economic loss as a result of these libelous publications. 2 . The public entities and/or employees alleged to have contributed to my client's injuries, damages and losses are those individuals employed by the Township of Galloway; including but not limited to Councilman Jim Gorman, and any and all agents and officers of the Township of Galloway who caused and otherwise facilitated the publication of libelous statements that have impaired my client's reputation and economic advantage by disclosing false and untrue information knowingly and/or in reckless disregard of such falsity. 2 The full extent of my client's claims and injuries have yet to be determined and the claim is still under investigation in this office. Very truly yours, 8S) Cc: Municipal Clerk, Kelli Danieli Cc: Donald Purdy