greg whitaker v. civitas solutions, inc., new jersey department of children and families
TRANSCRIPT
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8/20/2019 Greg Whitaker v. Civitas Solutions, Inc., New Jersey Department of Children and Families
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ST RK 8
ST RK
ATTORNEYS AT
LAW
MAILING ADDRESS
PO
BOX 53 5
PRINCETON, NJ 08543-5315
STARK STARK, A Professional Corporation
Mailing_Address: PO Box 5315, Princeton, NJ 08543
Office Location: 993
Lenox
Drive, Lawrenceville, NJ
08648
(609) 896-9060
Michael G. Donahue, III , Esq., Attorney ID : 04577-1994
Attorneys for Plaintiff
GREG
WHITAKER,
I
Plaintiff,
I
SUPERIOR COURT
OF
NEW
JERSEY
MERCER COUNTY LAW DNISION
vs.
CMTAS SOLUTIONS, INC ; THE MENTOR
NETWORK; NMH HOLDINGS, LLC; NATIONAL
MENTOR HOLDINGS, INC.; REM; NEW
JERSEY
MENTOR; REM NEW JERSEY; LISA McGEE;
LESTER J. WILLIAMS; STATE OF NEW JERSEY;
NEW JERSEY
DNISION
,OF YOUTH AND
F MILY
SERVICES;
NEW
JERSEY DIVISION
OF
CHILDREN AND FAMILIES; XYZ
CORPORATIONS 1-5 (fictitious designations); ABC
COMPANIES
1-10
(fictitious designations);
DEF
CONTRACTORS 1-10 (fictitious designations); and
JOHN DOES 1-10 (fictitious designations),
Defendants I
Defendants.
Docket.No. MER-L-43-16
CIVIL
ACTION
SUMMONS
From The
State of
New
Jersey
to The
Defendant(s) Named Above:
The plaintiffnamed above has filed a lawsuit against you in the Superior Court ofNew Jersey. The
complaint attached to this summons states
the
basis for this lawsuit. f you dispute this complaint, you or your
attorney must file a written answer or motion and proof
of
service with the Deputy Clerk of the Superior Court
in
the county listed above within 35 days from the date you received this summons, not counting the date you
received it.
(A
directory of he addresses of each Deputy Clerk of he Superior Court is available
in
the Civil
Division Management Office
in
the County listed above and online at http://www.judiciary.state.nj.us/pro
se/10153 deptyclerklawref.pdf.)
f
he complaint
is
one in foreclosure, then you must file your written answer or
motion and proof
of
service with the Clerk of he Superior Court, Hughes Justice Complex,
P.
0 Box 971,
Trenton,
NJ
08625-0971. A filing fee payable to the Treasurer, State ofNew Jersey, and a completed Case
Information Statement (available from the Deputy Clerk of the Superior Court) must accompany your answer or
motion when it is filed. You must also send a copy of your answer or motion to plaintiffs attorney, whose name
and address appear above, or to plaintiff,
if no
attorney is named above. A telephone call will not protect your
rights; you must file and serve a written answer or motion (with fee
of
$175.00 and completed Case Infonnation
Statement) if you want the court
to
hear your defense.
fyou do not file and serve a written answer or motion within 3 5 days, the court may enter a judgment against you
for the rel ief plaintiff demands, plus interest and costs of suit. f udgment is entered against you, the Sheriff may
seize your money, wages, or property
to
pay all or part
of
the judgment.
lfyou cannot afford an attorney, you may call the Legal Services office in the county where you live,
or
the Legal
Services ofNew Jersey Statewide Hotline, at 1-888-LSNJ-LAW(l-888-576-5529). f you do not have an attorney
and
are
not eligible for free legal assistance, you
may
obtain a referral to
an
attorney
by
calling one
of
the Lawyer
Referral Services.
A
directory with contact infonnation for local Legal Services Offices and Lawyer Referral
Services is available in the Civil Division Management Office in the county listed above and online at
h ://www:udici .state.n· .us/ rose/10153 de cler wref. df.
DATED: January
26, 2016
Name of Defendant to be served: New Jersey Division
of
Youth and Family Services
Address
of
Defendant to be served: 50 East State Street, 2nd floor, Trenton, NJ 08625-0729
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8/20/2019 Greg Whitaker v. Civitas Solutions, Inc., New Jersey Department of Children and Families
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MERCER COUNTY COURTHOUSE
•CIVIL CASE MANAGMENT OFFICE
175
SOUTH
BROAD ST PO BOX 8068
TRENTON
NJ 08650-0068
COURT TELEPHONE NO.
609)
571-4490
COURT HOURS 8:30 AM -
4:30
PM
DATE:
RE:
TRACK ASSIGNMENT NOTICE
JANUARY
11,
2016
WHITAKER V CIVITAS SOLUTIONS
INC
ET
AL
DOCKET:
MERL
-000043 16
THE
ABOVE
CASE
HAS
BEEN
ASSIGNED TO:
TRACK
2.
DISCOVERY IS 300
DAYS
AND RUNS FROM THE FIRST ANSWER OR 90
DAYS
FROM SERVICE
ON
THE FIRST DEFENDANT
WHICHEVER
COMES
FIRST.
THE PRETRIAL JUDGE ASSIGNED IS: HON
ANTHONY
M. MASSI
I YOU HAVE
NY
QUESTIONS, CONTACT TEAM 012
AT:
{609) 571.-4454.
I
YOU
BELIEVE
THAT
THE
TR CK
IS INAPPROPRIATE
YOU
MUST
FILE
A
CERTIFICATION OF GOOD
CAUSE
WITHIN 30
DAYS
OF THE FILING OF YOUR PLEADING.
PLAINTIFF
MUST SERVE COPIES OF
THIS
FORM ON ALL OTHER PARTIES IN ACCORDANCE
WITH
R.4:SA-2.
ATTENTION:
JUWSEB2
ATT: MICHAEL G. DONAHUE
STARK STARK
993 LENOX DRIVE
BUILDING 2
LAWRENCEVILLE NJ
08648
ece ven
N 15 2 16 u
. BY
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8/20/2019 Greg Whitaker v. Civitas Solutions, Inc., New Jersey Department of Children and Families
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Appendix Xll Bl
FILED
JAN
08
2016
CIVIL CASE INFORMATION STATEMENT
(CIS)
CHGICKNO.
CIVIL
DIVISION
Use for initial Law Division
AMOUNT:
Civil Part pleadings (not motions) under
Rufe
4:5-1
Pleading
will be
rejected
for
filing, under
Rule
1 5-6(c),
if information
above the
black
bar is not
completed
or
attorney's signature
is not
affixed
OVERPAYMENT:
BATCH
NUMBER:
ATTORNEY
I
PRO SE NAME
Michael
G.
Donahue, Esquire
FIRM NAME (if appficable) ·
Stark Stark, A Professional Corporation
OFFICE
ADDRESS
Stark Stark, p c
P
0.
Box 5315
TELEPHONE NUMBER
609) 895-7343
COUNTY OF VENUE
Mercer
DOCKETNUMBER when available)
L, 43 \
DOCUMENT
TYPE
Complaint
Princeton, NJ 08543-5315
JURY DEMAND
YES
O
No
NAME OF PARTY (e.g., John Doe, Plaintiff}
Greg Whitaker
CASETYPE NUMBER
(See reverse side for listing)
HURRICANE SANDY
RELATED?
CAPTION
Whitaker
v.
DYFUS, et
al.
IS THIS A PROFESSIONAL MALPRACTICE CASE?
O YES lgj NO
605
O
YES 181 NO
f
YOU HAVE
CHECKED
YES,~ SEE
N.J.S.A. 2A:53A-27 AND APPLICABLE CASE
LAW
REGARDING YOUR OBLIGATION TO
FILE
AN AFFIDAVIT OF
MERIT.
RELATED
CASES
PENDING?
D YEs [81 No
O
YOU ANTICIPATE ADDING ANY PARTIES
(arising out of same transaction or occl.lll3nce)?
O YES l8J No
IF YES,
LIST DOCKET NUMBERS
NAME OF DEFENDANTS PRIMARY INSURANCE COMPANY (if known)
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE.
CASE CHARACTERISTICS
FOR
PURPOSES OF DETERMINING IF
CASE
IS APPROPRIATE FOR MEDIATION
DO
PARTIES
HAVE
A CURRENT, PAST OR
IF YES,
IS THAT RELATIONSHIP:
O
NONE
UNKNO\NN
RECURRENT RELATIONSHIP?
D EMPLOYER/EMPLOYEE
D
FRIEN
1
D/NBGHBOR
D OTHER (explain}
DYES
181
No
D FAMILIAL
D
BUSlNESS
DOES THE STATUTE GOVERNING THIS CASE PROVIDE FOR PAYMENT OF FEES BY THE
LOSING PARTY? DYES 181
No
USE THIS SPACE TO ALERT THE COURT
TO ANY
SPECIAL CASE CHARACTERISTICS THAT MAY WARRANT INDIVIDUAL MANAGEMENT OR
ACCELERATED DISPOSITION
{5
Do
YOU OR YOUR
CLIENT NEED Af l Y
DISABILITY
ACCOMMODAllONS?
IF YES, PLEASE IDENTIFYTHE REQUESTED
ACCOMMODATION
DYES
No
WILL AN INTERPRETER
BE
NEEDED?
IF
YES,
FOR WHAT tANGUAGE?
DYES
~- No
I
certify
that confidential
pet +nal
,dentifiers
have been
redacted from
documents
now s·ubmitted to the
court,
and will be
redacted from all
documen~ Ubll)
itted in the future in accordance
with Rule
1 38-7(b).
/ ~
,
ATTORNEY SIGNATURE:
j
;.
I
Effective 05-04-2015, CN 10517-En lish
page
1
of2
.
J
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Side2
CIVIL CASE INFORMATION STATEMENT
(CIS)
Use for initial pleadings (not motions) under
Rule 4:5-1
CASE
TYPES (Choose one
and
enter number
of case
type
in
appropriate space
on the
reverse
side.)
Track
I - 150 days discovery
151 NAME CHANGE
175 FORFEITURE
302 TENANCY
399 REAL PROPERTY (othe r than Tenancy, Contract, Condemnation, Complex Commercial or Construction)
502 BOOK ACCOUNT (debt collection matters only) ·
505
OTHER INSURANCE CLAIM Oncluding declaratory judgment actions
506 Pf P COVERAGE
510 UM or UIM CLAIM (coverage issues only)
511 ACTION
O
NEGOTIABLE INSTRUMENT
512 LEMON
LAW
801
SUMMARY ACTION
802 OPEN PUBLIC RECORDS ACT (summary action)
999
OTHER (briefly describe nature of
action
Track II -
300
days' discovery
305 CONSTRUCTION
509 EMPLOYMENT (other than CEPA or LAD)
599 CONTRACT/COMMERCIAL TRANSACTION
603N
AUTO NEGUGENCE - PERSONAL INJURY (non-verbal threshold)
603Y
AUTO NEGLIGENCE - PERSONAL INJURY
verbal
threshold}
605
PERSONAL INJURY
610
AUTO
NEGLIGENCE PROPERTY
DAMAGE
621
UM or UIM
CtAfM
(includes
bodily
injury}
699
TORT - OTHER
Track Ill - 450 days' discovery
005
CIVIL RIGHTS
301
CONDEMNATION
602 ASSAULT AND BATTERY
604 MEDICAL MALPRACTICE
606 PRODUCT LIABILITY
607
PROFESSIONAL MALPRACTICE
608
TOXIC
TORT
609 DEFAMATION
616
WHISTLEBLOWER CONSCIENTIOUS EMPLOYEE PROTECTION ACT (CEPA) CASES
617
INVERSE CONDEMNATION
618 LAW
AGAINSTOISCRIMINATION
LAD)
CASES
Track IV - Active Case Management by Individual Judge 450 days' d iscovery
156 ENVIRONMENTAUENVIRONMENTAL COVERAGE LITIGATION
303
MT. LAUREL
508 COMPLEX COMMERCIAL
513 COMPLEX CONSTRUCTION
514 INSURANCE FRAUD
620 FALSE CLAIMS ACT
701 ACTIONS IN LIEU OF PREROGATIVE WRITS
Multicounty
Litigation {Track IV)
271 ACCUTANE/ISOTRETINOIN 289 REGLAN
274
RISPERDAL/SEROQUEUZYPREXA
290
POMPTON LAKES ENVIRONMENTAL LITIGATION
278
ZOMETNAREOIA 291 PELVIC MESH/GYNECARE
279
GADOLINIUM
292
PELVIC MESH/BARO
281 BRISTOL-MYERS SQUIBB ENVIRONMENTAL 293 DEPUY ASR HIP IMPLANT LITIGATION
282 FOSAMAX 295 ALLODERM REGENERATIVE TISSUE MATRIX
285 STRYKER TRIDENT HIP IMPLANTS 296 STRYKER REJUVENATE/ABG II MODULAR HIP STEM COMPONENTS
286 LEVAQUIN 297 MlRENA CONTRACEPTIVE DEVICE
287
YAZ/YASMIN/OCELLA
601
ASBESTOS
288
PRUDENTIAL TORT LITIGATION
623
PROPECIA
If you believe this case requires a track other than that provided above, ploase indicate the reason on Side
1,
in the space under Case Characteristics.
Please check off
each 'applicable
category D Putative Class Action
,
D·
Title
59
Effective 05-04-2015, CN 10517-English
page 2 of 2
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8/20/2019 Greg Whitaker v. Civitas Solutions, Inc., New Jersey Department of Children and Families
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STARK 8
STARK
PROF.E.S.S ON/\1. CORPORATION
ST RK
&
ST RK
Professional Corporation
FILED
JAN
o
8 2 16
SUPEkh..
n
....
..
.1vru OF NJ
MERCER
VICINAGE
CIVIL DIVISION
Mailing Address: P.O. Box 5315, Princeton,
NJ
08543-5315
Office Location: 993 Lenox Drive, Building 2, Lawrenceville, NJ
08648
(609) 896-9060
Attorneys for
Plaintiff
Michael G. Donahue, Esquire,
Attorney
ID#: 04577-1994
GREG WHITAKER I SUPERIORCOURTOFNEW
JERSEY
Plaintiff
j MERCER COUNTY
-
LAW
DIVISION
vs.
I
DocketNo L...,4~-\ o
CNITAS SOLUTIONS, INC.; THE :rvffiNTOR I
NETWORK; NMH
HOLDINGS, LLC;
j
CIVIL ACTION
NATIONAL MENTOR
HOLDINGS, INC.; l
1
• COMPLAINT AND JURY DEMAND
REM; NEW
JERSEY
lvffiNTOR; REM NEW
JERSEY;
LISA McGEE;
LESIBR
J.
I
WILLIAMS;
STATE
OF
NEW
JERSEY;
NEW 1
JERSEY DNISION
OF
YOUTH
AND
FAMILY
SERICES;
NEW
JERSEY
DIVISION
1
OF CIIlLDREN
AND FAMILIES; XYZ
CORPORATIONS 1-5 (fictitious designations);
ABC
COMPANIES 1-10 (fictitious
designations);
DEF
CONTRACTORS 1-10
(fictitious designations); and
JOHN DOES
1-10
I
fictitious designations),
Defendants
I
DEMAND FOR ANSWERS TO
INTERROGATORIES
ArroRN1:mrnw Plaintiff,
GREG
WHITAKER, residing at 851 Quinton Avenue
in
the City of Trenton,
MAILING ADDRJ:5S
PO JIOX 5315
County
of
Mercer, and State ofNew
Jersey,
byway of Complaint,
say(s):
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STARK S
STARK
PROF.E5S ONAL CORPORATION
ATTORNE1'5ATI..AW
MAIUNG ADDRESS
PO BOX 5315
JERSEY 08543 5315
FIRST COUNT
1
Defendants, CIVITAS SOLUTIONS, INC.; THE MENTOR NETWORK;
NMH
HOLDINGS, LLC; NATIONAL MENTOR HOLDINGS, INC.;
REM;
NEW JERSEY
MENTOR; and/or
REM
NEW JERSEY are related companies which operate in the State
of
New Jersey by providing home and community based health and human services, among other
services, to citizens of and individuals located in the State
of
New Jersey.
2. Defendants, NEW JERSEY DIVISION OF YOUTH AND FAMILY SERICES
and/or
NEW
JERSEY
DNISION
OF
CHILDREN
AND
FAMILIES
are
or
were
agencies
of
Defendant, STATE OF NEW JERSEY.
3. On or about January
12,
2014, Plaintiff, GREG WHITTAKER, was an invitee
· and/or lawfully on the premises known as a l\1ENTOR Network Home located at 49 Edgemere
Avenue,
in
the City
of
Trenton, County
of
Mercer, and State
of
New Jersey.
4. At
the same time, the aforesaid premises was owned, possessed, maintained,
established, evaluated, investigated, secured, overseen, supported, and/or otherwise controlled
by
Defendants, CIVITAS SOLUTIONS, INC.; THE :MENTOR NETWORK; NMH
HOLDINGS, LLC; NATIONAL MENTOR HOLDINGS, INC.; REM; NEW JERSEY
MENTOR; REM NEW JERSEY; LISA McGEE; STATE OF NEW JERSEY; NEW JERSEY
DIVISION OF YOUTH AND FAMILY SERICES; NEW JERSEY DIVISION OF
CHILDREN AND FAMILIES;
XYZ
CORPORATIONS 1-5 (fictitious designations); ABC
COMPANIES 1-10 (fictitious designations); DEF CONTRACTORS 1-10 (fictitious
designations); and JOHN DOES 1-10 (fictitious designations).
2
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ST RK
S
ST RK
PROFESSIONAL COIU OllATION
ATIORNEYS T L W
MAIUNG
ADDRESS
PO BOX 5315
N W
JERSEY 08543-5315
5. Defendants,
CIVITAS SOLUTIONS
INC.;
THE MENTOR NETWORK; NMH
HOLDINGS, LLC;
NATIONAL MENTOR
HOLDINGS, INC.; REM; NEW JERSEY
MENTOR;
REM NEW JERSEY; LISA McGEE;
STATE
OF
NEW JERSEY;
NEW JERSEY
DIVISION OF YOUTH AND FAMILY SERICES;
NEW
JERSEY DIVISION OF
CHILDREN AND FAMILIES; XYZ CORPORATIONS 1-5 (fictitious designations); ABC
COMPANIES 1-10 (fictitious designations); DEF CONTRACTORS 1-10 (fictitious
designations); and JOHN DOES 1-10 (fictitious designations), evaluated, provided services,
cared for the safety, and placed individuals including, but not limited to, Natavia Robinson and
her minor daughter, M.R., in the aforementioned MENTOR Network Home located at 49
Edgemere Avenue, in the City of Trenton, County of Mercer, and State ofNew Jersey.
6. Defendant,
LESTER
J. WILLIAMS is the father ofNatavia Robinson s minor
daughter, M.R.
7. At present, the identity(ies) ofDefendant(s), XYZ COPORATIONS 1-5
(fictitious designations), ABC COMPANIES 1-10 (fictitious designations), XYZ
CONTRACTORS 1-10 (fictitious designations), and JOHN DOES 1-10 (fictitious
designations), are unknown. As such, ABC COMPANIES 1-10 (fictitious designations), XYZ
CONTRACTORS 1-10 (fictitious designations), and JOHN DOES 1-10 (fictitious
designations), are fictitious designations, representing one or more individual(s), sole
proprietorship(s), association(s), limited partnership(s), general partnership(s), limited liability
company(ies) and/or corporation(s), which
in
any way owned, possessed, controlled,
maintained, provided investigations for, evaluated, provided security to, provided oversight,
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8/20/2019 Greg Whitaker v. Civitas Solutions, Inc., New Jersey Department of Children and Families
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STARK
8 STARK
PROFESSIONAL COR.l OllATION
ATTORNEYS ATl.l .W
MAILING ADDlUSS
PO BOX 5.315
NEW JERSEY 08543-5315
supported, or placed individuals in the premises known as a
MENTOR
Network
Home
at 49
Edgem ere A venue in Trenton, New Jersey.
8.
On
January 12, 2014, Defendant, LESTER J. WILLIAMS ep.tered the
aforementioned MENTOR Network
Home
located at 49 Edgemere Avenue,
in
the
City
of
Trenton, County of Mercer, and State of
New
Jersey, and sexually assaulted Natavia Robinson.
9. Later that same day, Defendant, LESTER
J.
WIL.LIAMS reentered
the
aforementioned
11ENTOR
Network
Ho~e
located at 49 Edgemere Avenue in
the
City
of·
Trenton,
County
of
Mercer, and State
of
New
Jersey
and
assaulted Plaintiff,
GREG
WHITAKER causing severe and permanent injury.
10.
The
aforesaid occurrence w s caused by the negligence of Defendants,
CIVITAS SOLUTIONS INC.; THE .MENTOR NETWORK;
NMH
HOLDINGS LLC;
NATIONAL MENTOR HOLDINGS INC.; REM; NEW JERSEY
MENTOR; REM
NEW
JERSEY; LISA McGEE; LESTER J. WILLIAMS; STATE OF
NEW
JERSEY;
NEW
JERSEY DIVISION OF YOUTH AND FAMILY SERICES;
NEW
JERSEY DMSION OF
CHILDREN AND FAMILIES; XYZ CORPORATIONS 1-5 (fictitious designations); ABC
COMPANIES 1-10 (fictitious designations); DEF CONTRACTORS 1-10 (fictitious
designations);
and JOHN
DOES 1-10 (fictitious designations), their agents, servants and
employees, who had inadequate security and controls in place to protect its invitees, residents
and
visitors against the foreseeable conduct an.cl/or actions
of
Defendant, LESTER
J.
WILLIAMS
and/or other individuals who may be reasonable anticipated to perform violent
and/or dangerous acts against invitees, residents, and/or visitors
of
the premises; and who
provided inadeq.uate· investigation and/or monitoring of the foreseeable danger to residents
4
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ST RK ?, ST RK
PRO 'ESS ONAL
CORPOMTION
ATTORlJEn
T
LAW
MAILING
ADDRESS
PO BOX 5315
NEW JERSEY 8543·5315
including, but not limited to, Natavia Robinson by Defendant, LESTER J. WILLIAMS, and/or
other individuals who may be reasonable anticipated to perform violent and/or dangerous acts
against invitees, residents, and/or visitors
of
the premises; by failing to intercede and protect
invitees, residents, and/or visitors including, but not limited to, Plaintiff, GREG WHITAKER,
from the threatening and/or assaultive behavior of Defendant, LESTER
J
WILLIAMS; by
failing to engage in background checks or other diligent and necessary investigations and
evaluations to determine the likelihood
of
dangerous and potentially injurious conduct of
Defendants, LESTER J. WILLIAMS, and/or other individuals who may be reasonable
anticipated
to
perform violent and/or dangerous acts against
invitees,
residents, and/or visitors
of the premises and by failing to otherwise properly monitor and secure the premises; in failing
to provide adequate security and safety measures at the premises despite knowledge of a risk of
danger and assault at the premises; and otherwise in failing to exercise due care under the
circumstances.
11. As a result of the carelessness, recklessness, and negligence of Defendants,
CNITAS
SOLUTIONS, INC.; HE
MENTOR
NETWORK;
NMH
HOLDINGS;, LLC;
NATIONAL :MENTOR HOLDINGS, INC.; REM; NEW JERSEY MENTOR; REM NEW
JERSEY; LISA McGEE; LESTER
J
WILLIAMS; STATE OF
NEW
JERSEY;
NEW
JERSEY DIVISION OF YOUTH
AND FAMILY
SERICES;
NEW
JERSEY DIVISION OF
CHILDREN AND FAMILIES; XYZ CORPORATIONS 1-5 (fictitious designations); ABC
COMPANIES 1-10. (fictitious designations);
DEF
CONTRACTORS 1-10 (fictitious
designations); and JOHN DOES 1-10 (fictitious designations), their agents, servants and
employees, and their disregard for the safety of others, Plaintiff,
GREG
WHITAKER, was
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.STARK 8 STARK
CORPORATION
TTORNEYS AT L W
MAILING ADDRESS
PO BOX 5315
JERSEY 08543-5315
caused to suffer severe bodily injuries, some
of
which are permanent
in
nature, has been caused
and
will
be
caused
to
expend large sums
of money
for medical treatment necessary to effect a
cure for his injuries,
has been
caused and
will in the
future
be
caused great pain
and
suffering,
has been caused
and
will
in
the future
be
caused
to
be unable to pursue his usual activities,
and
has been
and
will
in
the future
be
caused to lose large sums
of
money due
to
his inability
to
pursue his usual occupation.
WHEREFORE, Plaintiff,
GREG WHITAKER
demands Judgment for damages
generally against
the
Defendants, CIVITAS SOLUTIONS, INC.;
THE MENTOR NETWORK;
NMH
HOLDINGS, LLC;
NATIONAL MENTOR
HOLDINGS, INC.;
REM;
NEW JERSEY
MENTOR;
REM
NEW
JERSEY; LISA McGEE;
LESTER J
WILLIAMS; STA
TE
OF
NEW
JERSEY; NEW
JERSEY
DIVISION OF
YOUTH
AND
FAMILY
SERICES;
NEW JERSEY
DMSION
OF
CHILDREN AND
FAMILIES; XYZ CORPORATIONS 1-5 fictitious
de~ignations);
ABC COMPANIES
1-10 fictitious designations);
DEF CONTRACTORS
1-10
fictitious designations);
and JOHN
DOES 1-10 fictitious designations), individually, joint ly,
severally,
or
in the alternative, together with interest and costs
of
suit.
AHUE
JURY DEM ND
Plaintiff,
GREG WHITAKER
hereby demands a trial
by jury
as
to
all issues.
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STARK 8 STARK
PR OFE SSIONAL
CORPORATIO~
TTORNEYS AfLAW
MAILING DDRESS
PO BOX 5315
CERTIFICATION OF OTHER ACTIONS/PARTIES
Pursuant to the provisions
of
Rule
4:
5-1, the undersigned attorney certifies that this
matter
is not
the subject ofany other
action
pending in any court or
arbitration
proceeding, nor
is
any
other action or arbitration proceeding contemplated,
and all
known necessary parties
have beenjoined in this action.
CERTIFICATION OF COMPLIANCE WITH RULE l:38-7 c) l)
Pursuant to Rule 1 38-7 b), all
confidential identifiers
of the parties to
this action have
or will be redacted from all documents or pleadings submitted
to
the court.
DESIGNATION OF
TRIAL COUNSEL
Pursuant to the provisions ofRule 4 25-4 the Court is advised that Michael G Donahue,
Esq. is hereby designated as trial counsel.
DEMAND FOR
ANSWERS
TO INTERROGATORIES
Plaintiff, GREG WHITAKER, demands that Defendant, CIVITAS SOLUTIONS, INC.;
THE MENTOR NETWORK; NMH HOLDINGS, LLC; NATIONAL MENTOR HOLDINGS,
INC.; REM; NEW JERSEY MENTOR; REM NEW JERSEY; LISA McGEE; LESTER
J
WILLIAMS; STATE OF NEW JERSEY; NEW JERSEY DIVISION
OF
YOUTH
AND
54
•
5315
FAMILY SERICES; and NEW JERSEY DIVISION
OF
CHILDREN AND FAMILIES,
provide answers to interro~atories as follows:
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12/23
ST RK
8
STARK
l ROFESSIONAL COR.l ORATION
nolUIEYS T
UM
M/\JUNG AODRl:SS
PO OX 5315
JERSEY 08543-5315
FORM C and
FORM
C(2) UNIFORM INTERROGATORIES, as set forth
in
Appendix
II
of
the
New
Jersey Court Rules effective September 1, 2008.
Dated: January 7, 2016
STARK
A Professio
Attorneys£
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ST RK 8
ST RK
PROFB5 0NAI. CORPOIVI.TION
ATTORNEYS
T
LAW
MAILING
ADDRESS
ST RK
ST RK
Professional Corporation .
. Mailing Address: P.O. Box 5315, Princeton, NJ 08543-5315
Office Location: 993 Lenox Drive, Building 2, Lawrencev~lle, NJ 08648
( 609) 896-9060
Attorneys for Plaintiff
Michael
G.
Donahue, Esquire,
Attorney
ID#: 04577-1994
I
GREG
WHITTAKER SUPERIOR COURT
OF NEW
JERSEY
Plaintiff MERCER COUNTY - LAW DIVISION
vs.
CIVITAS SOLUTIONS, INC.; THE 11ENTOR
NETWORK; NMH HOLDINGS, LLC;
NATIONAL MENTOR HOLDINGS, INC.;
REM;
NEW
JERSEY tvfENTOR;
REM NEW
JERSEY; STATE OF NEW JERSEY; NEW
JERSEY DIVISION OF YOUTH AND
FAMILY SERICES; NEW JERSEY DIVISION
OF CHILDREN AND FAMILIES; LISA
McGEE; LESTER J. WILLIAMS;
XYZ
CORPORSTIONS 1-5 (fictitious designations);
ABC COMPANIES 1-10 (fictitious
desigr:i.ations);
DEF CONTRACTORS 1-10
(fictitious designations); and JOHN DOES 1-10
(fictitious designations) ,
To: CIVITAS SOLUTIONS, INC.
THE
MENTOR NETWORK
NMH HOLDINGS, LLC
Defendants I
NATIONAL MENTOR HOLDINGS, INC.
REM
NEW JERSEY MENTOR
STATE OF NEW JERSEY
Docket
No.
CIVIL
ACTION
DEMAND FOR DISCOVERY
OF INSURANCE COVERAGE
NEW JERSEY DIVISION
OF
YOUTH AND FAMILY SERICES
NEW JERSEY DIVISION OF CHILDREN AND FAMILIES
LISA McGEE
LESTER J. WILLIAMS
Pursuant to Rule 4:10-2(b), demand
is
hereby made that you disclose
to
the undersigned
whether there are any insurance agreements
or
policies under which any person or firm
carrying on an insurance business may be liable to satisfy part or all
of
a Judgment which may
be entered in this action or to indemrufy or reimburse for payments made to satisfy the
judgment.
YES ) NO ( )
f
he answer is yes attach a copy of each or in the alternative state, under oath
or
certification
(a) number
(b)
name and address of insurer or issuer (c) inception of expiration dates d) names
and addresses of all persons insured there under (e) personal injury limits (f) property damage
· limits (g) medical
_payment
limits h) name and address of person who has custody and
possession thereof (i) where and when each policy or agreement can be inspected and copied.
Po
aox
s31s
Dated
Nl:W JERSEY 08543·5315
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ST RK ST RK
Professional
orporation
Mailing Address: P.O. 'Box 5315, Princeton, NJ
0·8543-5315
Office Location: 993 Lenox Drive, Building 2 Lawrenceville, NJ 08648
(609) 896-9060 .
Attorneys for Plaintiff
Michael
G.
Donahue, Esquire, Attorney ID#: 04577-1994-
GREG WHITTAKER
I
Plaintiff
vs.
CIVITAS SOLUTIONS, INC.; THE MENTOR
NETWORK; NMH HOLDINGS, LLC;
NATIONAL MENTOR HOLDINGS, INC.;
REM;
NEW JERSEY MENTOR; REM NEW
JERSEY; STATE
OF
NEW JERSEY; NEW
JERSEY DIVISION
OF
YOUTH AND
FAMILY SERICES; NEW JERSEY DIVISION
OF
CHILDREN AND FAMILIES; LISA
McGEE; LESTER
J.
WILLIAMS; XYZ
CORPORSTIONS 1-5 (fictitious designations);
ABC COl\1PANIES 1-10 (fictitious
designations); DEF CONTRACTORS 1-10
(fictitious designations); and JOHN
DOES
1-10
(fictitious designations)
I
I
I
I
I
I
I
·
Defendants
i
TO: CIVITAS SOLUTIONS, INC.
THE
:rvIBNTOR
NETWORK
NMH HOLDIND, LLC
NATIONAL MENTOR HOLDINGS, INC.
REM
NEW JERSEY MENTOR
REM NEW JERSEY
STATE OF NEW JERSEY
SUPERIOR COURT
OF
NEW JERSEY
MERCER COUNTY - LAW DIVISION
Docket No.
CIVIL ACTION
PRODUCTION
O
DOCUMENTS
NEW JERSEY DIVISION OF YOUTH AND FAMILY SERICES
NEW JERSEY DIVISION OF CHILDREN AND FAMILIES
LISA McGEE
LESTERJ.WILLIAMS
.srARK
s sTARK
Pursuant to Rule
4:18-1, plaintiff request
production
of the
following documents
from
TION
AITORNEYS AT LAW
MAILING ADDRESS
PO
OX 5315
NEW
JERSEY
08543-5315
the defendant:
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8/20/2019 Greg Whitaker v. Civitas Solutions, Inc., New Jersey Department of Children and Families
15/23
STARK STARK
.ATTORNEY S AT
U.W
MAILING ADDRESS
PO OX 53 5
JERSEY
08543-5315
1. Please produce the deed showing defendant's ownership interest in
the
premises
as of the date of this incident.
2.
Attach
hereto any and
all
maintenance
records
or log
book or other
similar
documents generated by the defendant for the one
year
period prior to plaintiffs accident and
one month subsequent to plaintiffs accident.
3.
Attach
hereto a copy of any training materials or documents with respect
to
the
inspection procedure
to
be utilized
by
the defendant employees or training
manual with
respect
to the inspection
or
maintenance of the defendant premises.
4. Attach hereto any diary, log book or similar written record that describes the day
to
day
events
that take
place at defendant's premises.
5. Attach hereto copies
of
incident reports, pleadings, interrogatories,
and
deposition transcripts
from
any incident,
claim
or
lawsuit
which has ever arisen
out of
an injury
sustained on
defendant s
premises from slipping, tripping, or
other
alleged acts
of improper
design, maintenance, inspection, or construction.
6.
Attach
a
copy of all incident reports concerning
plaintiffs
claim.
7. Attach a copy of any excess insurance policy.
8.
Please
produce the following
in regard
to any surveillance conducted
of
the
Plaintiff:
a)
Any and all logs, notes, audio tapes, invoices, billing receipts or
documents that
were kept
concerning
the
filming of he videotapes
or
other surveillance that
did
not
result in videotape.
b)
A
list of
all teams, members
and
other personnel involved in the filming
of
the videotapes
along
with
the
times those individuals were involved in the taping, the
-2-
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8/20/2019 Greg Whitaker v. Civitas Solutions, Inc., New Jersey Department of Children and Families
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ST RK S ST RK
PROFE.'iS ONAL CORPOllATlO N
A
TTOR.NEYS
ATLAW
M IUNG ADDRESS
PO
BOX 5315
J RS Y 08543·5315
location of those individuals were involved in the taping, the location of those individuals at the
time of he taping and what,
if
anything, those individuals were instructed to observe.
c
A list of all people involved
in
the editing and/or copying, and/or
transferring
of the videotapes along with the times they worked on said videotapes and a
detailed description
of what
they edited to include:
i) Portions
of
original tape removed;
ii
Voice-overs;
iii) Portions
of
the tape clarified;
iv) Any other editing job performed by these individuals.
d) A
list
of all people speaking on the tapes and what times those people
were present for filming or editing.
e)
A description
of
what is contained on the videotapes.
f
n
explanation
of
what is contained
on
the videotapes.
g
A detailed explanation
of
what the defendant claims is shown
by
the
videotapes.
h
A labeled set ofvideotapes with each tape marked as to its contents.
i)
A list
of
all people associated
with
tlie filming, editing, production,
viewing, delivery and otherwise involved in any manner with the videotapes and when each
person was involved with said tapes and what they did with
or
to said tapes.
j A list of all the equipment used
in
the filming
of
the videotapes including
the model numbers
of such
equipment.
k
All correspondence regarding the videotaped surveillance and any other
surveillance which may
have
resulted in videotape.
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8/20/2019 Greg Whitaker v. Civitas Solutions, Inc., New Jersey Department of Children and Families
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STARK 8 STARK
PROFESSIONAL COR:POR..ATION
ATTORNEYS
AT LAW
MAILING ADDIU:S.5
PO
OX 5315
NEW
JERSEY 08543 5315
I
All still photographs.
9. f
you allege any
of
the injuries plaintiff contends were caused by the incident
in.
issue were not caused by incident/accident, please produce the following documents:
a Copies
of
all medical reports and documents upon which
you
rely;
b Copies
of
any and all pleadings, interrogatories~ depositions or trial
transcripts or any other records upon which you will rely.
10. f
you allege the plaintiff has been involved
in
any previous or subsequent
accidents or incidents or sustained any previous or subsequent injuries to those in question,
please produce the following:
a Copies
of
all medical reports and documents upon which
you
will rely;
b Copies
of
any pleadings, interrogatories, depositions, trial testimony or
any other records upon which you will rely.
11.
f
you intend to cross-examine any
of
the plaintiffs experts by use
of
any
medical
or
scientific treatises or any treatises, please attach copies
of
said documents.
12. Please attach copies
of
any photographs, videos, surveillance films, audio tapes
or any other pictures, whether still
or
moving, regarding any aspect of the happening of the
accident or
of
he injuries and disabilities incurred by the plaintiff.
13.
f
you allege the plaintiff made any written admissions or declarations against
interest as to the happening
of
the accident or the injuries sustained
in
the accident, please
produce copies
of
any document containing such admissions or declarations against interest.
14.
f
you allege that any of he plaintiffs medical treatment was unnecessary,
unreasonable or not related to the accident/incident forming the basis
of
this complaint, please
attach copies
of
all documentation upon which you ~11 rely to support this alle_gation.
4
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8/20/2019 Greg Whitaker v. Civitas Solutions, Inc., New Jersey Department of Children and Families
18/23
STARK 8
STARK
l ROfESSIONAL CORPORATION
,..-rro~EYS T
L/\W
.{/\.JUNG
ADDRESS
P BOX5 J5
NEW
JERSEY
08543·5315
15. fplaintiff is asserting a loss wage claim and
you
allege that the plain tiff was not
disabled for ny of the period of ime claimed, please atiach copies
of
any documentation up~n
which your allegation is based.
16. f
you
allege that plaintiff had
any
pre-existing medical condition, please attach
copies
of
any medical records or any other documentation upon which you intend to rely to
support this allegation.
17. Please attach copies of all defense medical examinations.
18. Please attach copies of any medical examinations performed at the request of
any person or entity not a par ty to this matter.
19. Please produce copies of any and all documents received from any subpoena or
authorizations served in this matter.
20. Please
attach
copies of all written witness statements.
21. Please produce copies
of
any
and all statements taken from
any
of your
employees as a result
of
this accident.
22. Please produce copies
of
all statements
taken
by
you~
or
anyone acting
on
your
behalf,
or by
any party
to
this action, regarding the happening of this accident.
23. Please attach copies of any reports made to anyone concerning the incident
which is the subject matter of his suit.
Dated: January 7, 2016
5
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1496
LEGAL AID AND LEGAL SER.VICES
LEGAL
AID AND
LEGAL
SERVICES
Legal Center for
DeleDM.
of Llfey
Inc.
65
MadiM>n
Ave.
Morristown
07960
(973J984-0725;F~:(973)984-3168
Exec. Dtr.,: Edward J. Gilhooly
Litigr;.Jiorr involving rtprod ctive·relaltd a11d ,m.d. of
l;fi -rtlaUd
Leaal Servke.of New
Jene,,
Ino.
1-00Metroplu Dr. at Phi.infield
Ave.,
Suite 402.
P.O.
Box
1357,
Edison
08818-135'1
('iS2} 572-910 ,
Fax: (732) 572-0068
E-mail:
Internet: www.lanj.org
~ U2d C..l'Ml al Co«.U1Mb~Vllle D. Mill•r,
Jr.
Exec. V.P. and AAt.
General Cou.ueb Dawn K. Mffler
Sr.
V.P.
u d AM. Couuiel:
Cta1.1dine
Langrin
V.P. 1 and Aat.
6 t ta l
COllJI.Mh
Hmia David
Connie
Puca1e
JoAnne M81\ts Hat'OM
L.
Rnberu;ttrin
KrimaA
Mateo Rita ~ N a ' I M
v.P.
uc1
Senl6a- CounM l:
Leiahton
A. Holnus
S-...A.U ..:
May J,
Acii,vedo
Michele Olvera
c.
,pl\ Almooor Orlo,rw
A.odrff A.uerbeth Sbeni1
Recldotd
Timothy l. .8loc:k Jdaute Se.Merl
o.boru
Fenuelly
Schore
Den; Fenvo
St.ephamc
lJac1a M.
G.uibaldi R4Mt,do
R. Socuru
1 UCM Harrilon
Jo.bu.
8pieJhera
Murvtt I.ur.ik Ju40W
Jame1 TNaoor
M Jy ld. MeMaaw.Smith Cary Winalow
Dmcl McJe1in
1Wth.TaJw.. 6 S. Laurel St., B~ 6302
8S6)~7
~Atiye4
Di . -Ddbr
~ R . D d x i
lapidD ~
A tt~~
EaoAhd.4..-
Und
Bdleckl
Milv•L.Diu
SamirLollt
SWIAtt,s.:
Mqdl]ena Batt.a.a
Lblo h
8-e.1
Bauel
Muprt t Careioli
Maura A. CaroMl1i
Anne CnJle
Daniel Florio
Yolanda Goawu
Doqlu~·
Monica Gural
Elliot
D. Heme
Step.bani•
Hosea
RaquibaHuq
S.l'ah H:,mowits
o.m.tleJc:.ph
Xatherin.e8. Kolon
K.atie lon
.Alice KW'Onf
KArrin
lhbkemano
Shannon MtGiM
X.thleea
Petenoo
J.ocelp Pridtlen
Am..Rahiaa
JeyuthJ
Rajaraman
Annie
Mot
R waon
.Akil Ropet-
Ra.cbsl
B Sd ar
John A.
Saloit
Annie
B. Smith
EmiIT Twli. 6
S. Laurel
St.., Bridpton 08302
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LEGAL
AID
AND
LEGAL
SERVICES
1497
BERGEN COUNTY
County Q>mmunib
Mental H .ttb
aw Project
3271:lut RidgewQQd
Ave.,
Suite 201, Paramwa 07652-489.5
ZOl)
634-2761, 62;
Fu:
~l)
63+3003
Project
Dir~
Ern~t
A
Ville., Jr.
SWfAUya :
Meliaaa
H. De rtolo
HarryJ. Kau
Dn ald J. Lenrter
Men.tolHeaUh Social
Securib
lMabiliiy.
Mtdico.id
«iiaue
U
Famil J
lJJW
oJ?d
Othir
Enti tnfflU.
BUJlL NGTON
COUNTY
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H~J_8_ _ _
----·
LEGAL
AID AND tEGAL
SERVICES
Deann WeLih, Ext. 6477; E·rnail: dwalsh@Ji;nj.nrg
Fana Wray, Ext.
6476;
E--mail:
fwray@l~.nj.org
Al80 serves
county of
Sale~
Workm rig.hu, ,;taitwic:k
.ESSEX
COUNTY
.E ~
County Leia.J Aid AMociatioJl
.HaU ot~
oom
118,
465
Or. Martin Luthe- King BlTd . Newark 07102
(973) 622.()()63; Info
Line:
(973) 62.2-1513~
Fax:(973)622-2699
Ex~ Dir.: Marjorie
l..ie'I)'
220-2694
Supervitm(
Atty.:
Ingrid Enriquei
Atty.:
Gl.ad:,3 Moriarty
L:uuJ].Qrd/ .lmo11t, Famil,- Om4umu
A/fillaud
with uu
COUllty
Bar~ on
ENes-Newars.Leol
Senicff
SCommerce St., 2no. Floor, Newark 07102
(973)
62-44600;
Fa: (973)
fiU.87 6
Exec. Dir.: Felipe CbavanA;E-mail: fchavan11@1. nj..org
ldamliq Atty..
Elda
a11r Ra.chMl M. Balde
Fu: (973)
648,-0565
Maa.a,iq
A-U,,., Jl"amDy L ,n
Jainet
Lubrich
Fu:~973}62 -~li
Lall Edumtia11Law.
Elcut-1.Au
Family
Law,
Gowl IURfflf
lhM{iu
HtaW UU & Law
GLOOCESTF.11.
COUNTY
8Gatla
J4rMY
i . , . . i
Serrice,. lac.
41~
Ave
•
_Woodhw:y
08096
(85e) ~ F u : C ~ ~
Mln•o,,• CoaaM M. Saile.Y Ext. 6828
S . I A « i l: ~ O l f
Stall ~
Julie heetAd. Ext. 6830; X-mai l : j f~leQj .orr
Lqju.u Lee.
Ezt.. '826; E-awl:
Limited
ewa 1.ttfft
BlJDSON
COt1NTY
c.au.nmltyB- d t
Law~
Ulliall A B..a.oaC - U •
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N..-dl•••tNew
. ,_ . . , LepJ
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574 s...ttAve..
City 1~
(201) m..6S6S; Fa: 2111) 198-8780
hea. OW.Jahn
H. F i t l p r . i d ; . E - m c 1 : j f i ~ e t ;
Dm·
rtsDieboldiE-cnail:
Ciuil
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22/23
L.ECAL
AJD
AND .LEGAL SERVICES __
·· _
· ____
.
145.19
MIDDLESEX
COUNTY
OCEAN COUNTY
Conimunity
H~lth La,-,
P t oject
Monmouth Oeun Count ies Office
Su
Monmouth ounty
~eao-Mon..m.ouib Legal
Service.. Inc.
599 ate
37 W.,
2nd
Floor, Tums
River 08761 >
(782) 3-(1~2727;
Fu:
1732 5~3080; M'Y:
(732}
341·0526
Deputy
Dir. and Oil . of UUpdon: Marla LaFace
g-n.
731'4;
E-mail: ml~Jsnj or t
A.Uy~
RebcK:t:a
Gumann.
En
7313
E-mail [email protected]
PASSAIC COVNl'Y'
Coma.ordi.1 lwdth Law Project
EMU
Puuic
Couotiel
S«
Bun O ltUy
NorihNMN.11' JflMT Lepl Sernccc
Putaic Colll V DimiQn
152
.Market.st:..
6tb Floor. PaW IOn
07505
{973)
m 2900;
Fu: (913)
523-9002
Deputy Dir.:
Ma.
Nunin Saifi
E-mail: mai6elsn,i.orr
SALEM
COUNTY
Soa.Ua Jffftey Lepl Senlce.. Inc.
t
tmtbuhmd
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23/23
--~t..A :..::..W'.YER REP~RRAL S ERV1CES
LAWYER REFERRAL SERVICES
Me~r Counir
.Aieoci.ation
Lawyer
Relerr .1 Servic11
l 24:6
Whitehorse .Mertenille
Rd • Suito 420,
Hamilton
08619-3894
(609)685-6200;Fax:(609J585-5S37
E·uial1:
infoOme~rhu.com
tntecnet: www.mercerhe..r.com
Dlrecton
Fnmd~
&walayk
MWdl~
Cunty
Bar
A.uoclat.ion
Lawy4r Referral Service
87 Bayard St.,
New
Brunswick 08901
(732) 828-0053
Internet:
www.incbalaw.COll l
Exec. Dir. i~thari P.
CowlM
E-mail: ja,wla@,rncbllaw.com
Adm:lnitriniori
Pattyann
Pu1 261 6882;
ru:
00 . 25
Cctot Clh:uat.er.
Luer
~
913) 267-6089,
Est.
12
Oe...
Coclllty Ber
AAociatloo.
La
1Wieffe1
rrioe
P.O. Box 381, 'lomt Rivm 087 3
732)~
Fmc 732}~
E-JMU:~
lCAtin Poola
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lAW)'Ct' Semoe
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HamiltoA
St..
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01506
(973)
21U228
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Weta~ iu A.tlodatloca
La lWen-1Senice
=-UM629
&mlenetCetmd.Y
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La,eyw
Rel«Tl1
S«vice
~
tb
flOOI.
20 N.
Bridp
St.,
P.O.
Box
1095,
·SomeniUo
GM1t.109
(908)686-~
Fu:
C908)
I n t e rne t ~
. . . . Hr.:
c.rotAml
Winder
E-awdl:~.com
Umoa C orm.ty
Bar
ANociatloa
Lawyer Rc«nal &nice
CourtbotMe. lat~
EUabetb
07307
(908) 363--1115; Fu:
(908)
SU-8222
kec.
DilnJeffrey
M.
Clar
.Ad.mini.nrator J'Ottar
Mon.·11u n. 10
u£ 1 P. IL
Wa.n'911 Comity
Bar ANodatioa
La Referral
Servica
.t13'1:::i St.., Behidere 07823
(908)-387-1836
.E.uw1.: w~tybarO:,aboo.cam
hec.Dir.:~cy
t
Presa Time