‘van S. Goddard Attorney at Law 12 South Washington Avenue P.O. Box 3227 Margate, NJ 08402 (5-422-4489 phone 9406-076 eal), (9422-498 tox March 15,2016 VIA CERTIFIED MAIL #7014 2870 0000 8632 1805, Attention: Legal Department - Tort Claims Robert Lougy, Acting Attomey General RY Hughes Justice Complex 25 Market Street P.O, Box 080 ‘Trenton, NI 08625-0080 RE: Felicia A. Abvams o/b/o AES EEE 2 minor v. Miss Hollys Daycare, et al, Docket No. not in suit DOL: 12/8/15 Our file: 2015-P1240 Dear Sir/Madam: Please be advised that this firm has been retained to represent claimant, = a minor, through her mother, Felicia A. Abrams, with regard to an injuring incident that occurred on or about December 18, 2015, in Cape May, New Jersey. As the claimant is a minor, the requirements of notice are tolled until the child reaches the age of majority. Nonetheless, and without waiving claimant's rights in that regard, we herein provide you with Notice. Pursuant to the notification requirements of the New Jersey ‘Tort Claims Act, N.J.S.A. 59:8-8 ef seq., you att hereby noticed as follows: NOTICE OF TORT CLAIM This is notice to you, pursuant to Nv.S.A, 59:1-1, of the assertion of a claim against you and the following information is submitted, pursuant to N.JS.A, $9:1-4: A. Claimant: Felicia A. Abrams > ae a minor, Woodbine Manor, 201 Webster Street, Apt. E-04, Woodbine, NY 08270. B.' Notic Alll Notice’ with respect to this claim are to be sent on behalf of claimant to Evan 8. Goddard, Esq,, at 12 South Washington Avenue, P.O. Box 3227, Margate, NJ 08402.County of Cape May-and/or State of New Jersey. C. Date, place and other circumstances of oceurrence or transaction: The subject injuring incident ocourred on or about December 18, 2015, The incident occurred while the infant was in daycare at Miss Holly's Daycare, 208 Lennox ‘Avemué, Cape May, New Jersey. Miss Holly's Dayoare is unlicensed by Department of Children and Families and owned by Holly Melo. Specifically, the claimant while in the care and custody of the Division of Child Protection and Permanency, and having been placed into the foster care, sustained serious and permanent injuries when she was left unattended in daycare and fell off a plastic play station and/or picnic table, Claimant was caused to fall and/or become injured as a direct and proximate result of a failure to supervise. Those responsible for failing to supervise the infant were negligent, careless, reckless and/or grossly negligent, Further, the Division of Child Protection and Permanency and State of New Jersey are responsible under alternative theories, including, ‘but not limited to, contract, vicarious liability and respondeat superior. The claimant; SJ GJ (DOB: 12/5/13), not yet two years of age at the time of this occurrence and/or accident, was unable to care for herself and/or appreciate the conditions which lead to her injuries and in no way contributed to her injuries. D. General description of .injuries, damages or losses known at the present time: ‘The claimant sustained personal injuries with attendant losses and medical ‘expenses and disability as a result of the subject injuring incident including, but not limited to, a right sided femur fracture necessitating emergency room treatment at Cape Regional Medical Center, transfer to Cooper Medical Center for surgery and follow up care which required and will continue to require medical care, consultation and treatment. Additionally, due to the age of the minor and nature of injuries, there exists a likelihood of resulting continued lifelong medical cate, consultation, treatment and disability. Other damages unknown at this time, Medical records are forthcoming and this information will be supplied as it develops and upon request. E. _ Name(8) of public entity employee(s) causing the injuries, damages or losses: Owner, operator, employees, agents and/or assigns of Miss Holly's Daycare and all others responsible for the care and supervision of claimant, Upon information and belief, the subject daycare and negligence, carelessness, recklessness and/or gross negligence giving rise to the subject injuring incident at the above mentioned place, time and dete were within the control and responsibility of Holly Melo, Miss Holly's Daycare, Department of Children aad Families, Division of Child Protection and Permanency, including Foster Caretakers, Casoworkers, Managers, Supervisors, City of Cape May, F, Amount presently claimed: Claimant seeks compensatory damages for pain, suffering, disability, loss of earnings or fture earnings capacity, medical expensesand other attendant losses stemming from the subject injuring incident without prejudice in the amount of ten million ($10,000,000,00) dollars. G. Estimated amount of prospective injuries, damages or losses: “Unknown at present H. Basis of computation of amount claimed: Damages are un-liquidated, ‘Thank you for your careful attention in this matter. If you have any questions, please do not hesitate to contact me at my office or on cellular at 609-804-1076, Dated: March 15, 2016 Senti via cortfied & regular mail :VIACERTIFIED MAIL #7014.2870 0000 8632 1812 Miss Hollys Daycare 208 Lennox Avenue Cape May, NI. 08204 VIA CERTIFIED MAIL #7014 2870 0000 8632 1829 Holly Melo 208 Lennox Avenue Cape May, NJ 08204 VIA CERTIFIED MAIL #7014 2870 0000 8632 1836 Allison Blake, Commissioner Department of Children and Families P.O. Box 729 ‘Trenton, NI 08625-0729 VIA CERTIFIED MAIL #7014 2870 0000 8632 1843 Diane Rhile, Manager Cape May Local Office #761 Division of Child Protection and Permaneney Court House Commons, Building B 601 Route 9 South Cape May Court House, NI 08210 VIA CERTIFIED MAL. #7014 2870-0000 86321850 Louise F. Cummiskey, Clerk City of Cape May 643 Washington Street Cape May, NI 08204‘VIA CERTIFIED MAIL #7014 2870 0000 8632 1867 Anthony P. Monzo, Eso, Solicitor for City of Cape May 211 Bayberry Drive, Suite 2A ‘Cape May Court House, NJ 08210 VIA CERTIFIED MAIL #7014 2870 0000 8632 1874 Rita Marie Fulginiti, Clerk Cape May County 7 North Main Street DN. P.O. Box 5000 Cape May Court House, NJ 08210 VIA CERTIFIED MAIL #7014 2870 0000 8632 1881 James B. Arsenault, Jr, Esquire Acting County Counsel County of Cape May 4 Moore Road Cape May Court House, NJ 08210 VIA CERTIFIED MAIL #7014 2870 0000 8632 1898 Govemor Chris Christie 125 West State Street P.O. Box 001 Trenton, NJ 08625 VIA CERTIFIED MAIL #7014 2870 0000 8632 1904 Attention: Tort Claims Unit Department of Treasury Bureau of Risk Management P.O. Box 620 Trenton, NJ 08625 Client/File/Notice