Susan Scott DOL LPS State NJ US

UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT

No. 13-4429

TARA KING, ED.D, et al.,

Plaintiffs-Appellants,

v.

CHRIS CHRISTIE, et al.,

Defendants-Appellees.

ON APPEAL FROM THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
CIVIL ACTION NO. 13-5038

SUPPLEMENTAL BRIEF ON BEHALF OF DEFENDANTS-APPELLEES
AS REQUESTED BY THE COURT

JOHN J. HOFFMAN
ACTING ATTORNEY GENERAL OF NEW JERSEY
R.J. Hughes Justice Complex
25 Market Street, P.O. Box 112
Trenton, New Jersey 08625-112
609-292-8150 (Phone)
SUSAN.SCOTT@DOL.LPS.STATE.NJ.US
Attorney for Defendants-Appellees

Melissa H. Raksa
Assistant Attorney General
Of Counsel

Eric S. Pasternack
Susan M. Scott
Deputy Attorneys General
On the Brief
Case: 13-4429 Document: 003111699584 Page: 1 Date Filed: 08/05/2014
i

TABLE OF CONTENTS
Page

QUESTIONS PRESENTED ...................................................................................... 1

SUMMARY OF THE ARGUMENT ........................................................................ 1

ARGUMENT ............................................................................................................. 2

POINT I ................................................................................................. 2

SEXUAL ORIENTATION CHANGE EFFORTS
PRACTICED BY STATE-LICENSED MENTAL
HEALTH PROVIDERS FALL SQUARELY WITHIN
THE PROFESSIONAL SPEECH DOCTRINE. .................................. 2

POINT II ................................................................................................ 3

PROFESSIONAL SPEECH THAT IS INCIDENTAL TO
THE PROVISION OF PROFESSIONAL SERVICES IS
SUBJECT ONLY TO RATIONAL BASIS REVIEW. ........................ 3

CONCLUSION ........................................................................................................13

CERTIFICATION OF COMPLIANCE WITH RULE 32(a) ..................................14

CERTIFICATION OF COMPLIANCE WITH LOCAL RULE 31.1(c) ................15
ii

TABLE OF AUTHORITIES
Page

Cases

Accountants Socy of Va. v. Bowman,
860 F.2d 602 (4th Cir. 1988) ........................................................................ passim

Barsky v. Bd. of Regents,
347 U.S. 442 (1954) ................................................................................ 4, 5, 8, 12

Brodie v. State Bd. of Med. Examrs,
427 A.2d 104 (N.J. Super. Ct. App. Div. 1981) ..................................................... 4

Busch v. Marple Newtown Sch. Dist.,
567 F.3d 89 (3d Cir. 2009) ...................................................................................12

Centro Tepeyac v. Montgomery Cnty.,
722 F.3d 184 (4th Cir. 2013) .................................................................................. 4

Clark v. Jeter,
486 U.S. 456 (1988) .............................................................................................10

Coggeshall v. Mass. Bd. of Registration of Psychologists,
604 F.3d 658 (1st Cir. 2010) .................................................................................. 9

Conant v. Walters,
309 F.3d 629 (9th Cir. 2002) .................................................................................. 8

Garrison v. Louisiana,
379 U.S. 64 (1964) ................................................................................................. 6

Greater Balt. Ctr. for Pregnancy Concerns, Inc. v. Mayor & Council of Balt.,
683 F.3d 539 (4th Cir. 2012), ...............................................................................10

Lowe v. S.E.C.,
472 U.S. 181 (1985) ..................................................................................... passim

Moore-King v. County of Chesterfield,
708 F.3d 560 (4th Cir. 2013) ........................................................................ passim

iii

New York Times Co. v. Sullivan,
376 U.S. 254 (1964) ............................................................................................... 5

Ohralik v. Ohio State Bar Assn,
436 U.S. 447 (1978) .........................................................................................9, 12

Pickup v. Brown,
728 F.3d 1042 (9th Cir. 2013) ...................................................................... passim

Planned Parenthood of Southeastern Pa. v. Casey,
505 U.S. 833 (1992) .............................................................................. 2, 7, 10, 12

Prince v. Massachusetts,
321 U.S. 158 (1944) .............................................................................................12

Riley v. Natl Fedn of the Blind of N.C., Inc.,
487 U.S. 781 (1988) ............................................................................................... 4

Semler v. Oregon State Bd. of Dental Examrs,
294 U.S. 608 (1935) .............................................................................................12

Stuart v. Loomis,
2014 U.S. Dist. LEXIS 6194 (M.D.N.C. 2014) ..................................................... 4

Thomas v. Collins,
323 U.S. 516 (1945) ...........................................................................................2, 6

Thornburg v. American College of Obstetricians & Gynecologists,
476 U.S. 747 (1968) .............................................................................................11

Underhill Assoc. v. Bradshaw,
674 F.2d 293 (4th Cir. 1982) .................................................................................. 9

Watson v. Maryland,
218 U.S. 173 (1910) ............................................................................................... 4

Wollschlaeger v. Governor of Fla.,
__ F.3d __, __, 2014 U.S. App. LEXIS 14192 (11th Cir. 2014) .......... 5, 8, 10, 11

Wooley v. Maynard,
430 U.S. 705 (1977) ............................................................................................... 7

iv

Zahl v. Harper,
282 F.3d 204 (3d Cir. 2002) ................................................................................... 4

Statutes

N.J. Stat. Ann. 45:1-54, -55 ............................................................... 3, 11, 12, 13
1

QUESTIONS PRESENTED

What role does the doctrine of professional speech play in this case? If A3371
regulates speech and not merely conduct, how much protection does this speech
receive under the First Amendment? Are Plaintiffs free speech rights diminished
when they are speaking as licensed professionals in the course of treating clients?
SUMMARY OF THE ARGUMENT
Without conceding that sexual orientation change efforts (SOCE) are
speech, rather than conduct, for the purposes of this supplemental brief, the State
will address the Courts question of whether if SOCE counseling is speech is it
professional speech subject to lesser First Amendment protection? Under the
Courts inquiry, SOCE is professional speech that is incidental to the provision of
professional services and afforded no First Amendment protection. Therefore, whether
SOCE is considered conduct or professional speech incidental to treatment, the result
is the same: SOCE is not entitled to any First Amendment protection, and any
regulation thereof is subject only to rational basis review, which New Jerseys statute
readily survives.

2

ARGUMENT
POINT I

SEXUAL ORIENTATION CHANGE EFFORTS
PRACTICED BY STATE-LICENSED MENTAL
HEALTH PROVIDERS FALL SQUARELY WITHIN
THE PROFESSIONAL SPEECH DOCTRINE.

As early as 1945, Justice Jackson observed that the states have an interest in
shielding the public against the untrustworthy, the incompetent, or the irresponsible
[professional]. Thomas v. Collins, 323 U.S. 516, 545 (1945) (Jackson, J.,
concurring). Then in Lowe v. S.E.C., Justice White explained that one is engaged in
professional speech where he or she takes the affairs of a client personally in hand
and purports to exercise judgment on behalf of the client in the light of the clients
individualized needs and circumstances . . . . Lowe v. S.E.C., 472 U.S. 181, 228
(1985) (White, J., concurring). In such instances a professionals speech is incidental
to the conduct of the profession. Id. at 232. Put another way, in those instances the
speech rights of physicians are, for example, implicated, but only as part of the
practice of medicine. Planned Parenthood of Southeastern Pa. v. Casey, 505 U.S.
833, 884 (1992) (plurality opinion of OConnor, Kennedy and Souter, JJ.) (internal
citations omitted). Therefore, the professional speech doctrine applies when the
speaker is providing personalized advice [i.e., the professional service provided] in a
private setting to a paying client . . . . Moore-King v. County of Chesterfield, 708
F.3d 560, 569 (4th Cir. 2013).
3

Here, SOCE therapy falls squarely within the principles underlying the doctrine
of professional speech because the state-licensed mental health providers speech is
incidental to the professional service provided, i.e., mental health treatment.
Appellants give information and advice and counsel [to their clients] to help the
[clients] reach their ultimate goal and objectives, (T14:24-15:1), based upon the
clients individual needs and objectives. Therefore, Appellants take their clients
affairs personally in hand and exercise their professional judgment on behalf of the
client in the interest of the clients individual needs and circumstances. Lowe, 472
U.S. at 228 (White, J., concurring).
Accordingly, because SOCE therapy falls within the professional speech
doctrine, N.J. Stat. Ann. 45:1-54, -55 is a permissible regulation of the mental
health profession and does not violate the First Amendment.
POINT II
PROFESSIONAL SPEECH THAT IS INCIDENTAL
TO THE PROVISION OF PROFESSIONAL
SERVICES IS SUBJECT ONLY TO RATIONAL
BASIS REVIEW.

The First Amendment does not require that all speech by professionals be
subject to strict scrutiny review. Rather, the level of First Amendment protection
afforded depends upon the context in which the professional speech is uttered. To that
end, it is useful to view a professionals speech as falling along a continuum: (1)
where the professionals speech falls outside the confines of a professional
4

relationship, it is subject to traditional First Amendment analysis; (2) where the
professionals speech occurs within the confines of a professional relationship, but is
not incidental to the services provided by the professional, it receives diminished First
Amendment protection; and (3) where the professionals speech both falls within the
confines of a professional relationship and is incidental to the professionals services,
it is subject only to rational basis review. In determining what level of First
Amendment scrutiny is to be applied to regulations impacting professional speech
within the confines of a professional relationship, courts take into account the
regulatory context, the nature of the professional relationship, the degree of intrusion
into the relationship, the reasons and evidentiary support for the intrusion, and the
connection between the [regulation] and the governments interests. Stuart v. Loomis,
2014 U.S. Dist. LEXIS 6194, *36-37 (M.D.N.C. 2014) (citing Riley v. Natl Fedn of
the Blind of N.C., Inc., 487 U.S. 781, 796 (1988); Pickup v. Brown, 728 F.3d 1042,
1053-55 (9th Cir. 2013); Centro Tepeyac v. Montgomery Cnty., 722 F.3d 184, 193
(4th Cir. 2013) (Wilkinson, J., concurring)).
It is well-settled that the State has broad police powers in regulating the medical
profession. Barsky v. Bd. of Regents, 347 U.S. 442, 449 (1954); Watson v. Maryland,
218 U.S. 173, 176 (1910); Zahl v. Harper, 282 F.3d 204, 211 (3d Cir. 2002) (citing
Brodie v. State Bd. of Med. Examrs, 427 A.2d 104, 108 (N.J. Super. Ct. App. Div.
1981). [A] states legitimate concern for maintaining high standards of professional
5

conduct extends beyond initial licensing. Barsky, 347 U.S. at 451. Under the
professional speech doctrine, the government can license and regulate those who
would provide services to their clients for compensation without running afoul of the
First Amendment. Moore-King, 708 F.3d at 569. As recognized by the Supreme
Court in Lowe, [t]he power of the government to regulate the professions is not lost
whenever the practice of a profession entails speech. Lowe, 472 U.S. at 228 (White,
J., concurring).
As such, the regulation of professionals speech necessarily involves the
collision between the power of government to license and regulate those who would
pursue a profession or vocation and the rights of freedom of speech . . . guaranteed by
the First Amendment. Lowe, 472 U.S. at 228 (White, J., concurring). Confronted by
this tension, courts have evaluated this collision along a continuum to locate the point
at which a measure is no longer a regulation of a profession but a regulation of
speech or of the press. Accountants Socy of Va. v. Bowman, 860 F.2d 602, 604 (4th
Cir. 1988) (quoting Lowe, 472 U.S. at 230 (White, J., concurring)); see also
Wollschlaeger v. Governor of Fla., __ F.3d __, __, 2014 U.S. App. LEXIS 14192,
*51-52 (11th Cir. 2014); Pickup v. Brown, 740 F.3d 1208, 1227-30 (9th Cir. 2014).
When a professional speaks to the public on matters of public concern, the First
Amendments protections are at their apex. Wollschlaeger, 2014 U.S. App. LEXIS
14192, at *51. See also New York Times Co. v. Sullivan, 376 U.S. 254, 270 (1964) (the
6

First Amendment embodies a profound national commitment to the principle that
debate on public issues should be uninhibited, robust, and wide-open.); Garrison v.
Louisiana, 379 U.S. 64, 74-75 (1964) (speech concerning public affairs is more than
self-expression; it is the essence of self-government.). As Justice White explained in
Lowe, Where the personal nexus between professional and client does not exist, and
a speaker does not purport to be exercising judgment on behalf of any particular
individual with whose circumstances he is directly acquainted, government regulation
ceases to function as legitimate regulation of professional practice with only incidental
impact on speech; it becomes [a] regulation of speaking or publishing. . . . Lowe, 472
U.S. at 232. Justice Jackson, similarly observed in Thomas, that while a state may
forbid one without its license to practice law as a vocation, . . . it could not stop an
unlicensed person from making a speech about the rights of man or the rights of labor,
or any other kind of right, including recommending that his hearers organize to
support his views. Thomas, 323 U.S. at 544-45 (Jackson, J., concurring). Thus,
outside the doctor-patient relationship, doctors are constitutionally equivalent to
soapbox orators and pamphleteers, and their speech receives robust protection under
the First Amendment. Pickup, 740 F.3d at 1227-28.
When speech by a professional is not incidental to the provision of the
professionals services, or a course of treatment, but occurs within the confines of the
professional relationship, the First Amendments protections are diminished and
7

legislation here is reviewed for reasonableness, at most.
1
Id. at 1228. At this point on
the continuum, the First Amendment tolerates a substantial amount of speech
regulation within the professional-client relationship that it would not tolerate outside
of it. Pickup, 740 F.3d at 1228. This is reasonable because [w]hen professionals, by
means of their state-issued licenses, form relationships with clients, the purpose of
those relationships is to advance the welfare of the clients, rather than to contribute to
public debate. Id.
In Casey, the Plurality observed that an informed consent requirement
implicated the physicians First Amendment rights only as part of the practice of
medicine, subject to reasonable licensing and regulation by the State. Casey, 505
U.S. at 884 (plurality opinion of OConnor, Kennedy and Souter, JJ.). Such a
requirement would, as the Plurality observed, almost certainly be deemed
impermissible compelled speech if it were outside the context of a professional
relationship. Id. (citing Wooley v. Maynard, 430 U.S. 705 (1977)).
While, at first blush, it appears that the Ninth Circuits holding in Conant v.
Walters, is inconsistent with Casey, a closer review reveals that the Ninth Circuit
applied heightened scrutiny due to the federal governments lack of police power to
regulate the medical profession and because the restriction on speech interfered with

1
This is not to say that this category of professional speech falls directly at a
midpoint on the continuum between the two ends, or that it is somehow entitled to
heightened First Amendment scrutiny, but merely to note that the professional speech
uttered here varies by its nature from the ends of the continuum.
8

the states interest in ensuring the provision of medically competent care. Conant v.
Walters, 309 F.3d 629, 638-39 (9th Cir. 2002); Wollschlaeger, 2014 U.S. App. LEXIS
14192, at *72. There, the Ninth Circuit enjoined a federal policy that prohibited
doctors from merely recommending marijuana to patients. Conant, 309 F.3d at 638-
39. Having observed that the states [are] the primary regulators of professional
conduct[,] the Ninth Circuit found that the application of heightened First
Amendment scrutiny was consistent with the principles of federalism. Id. The Ninth
Circuits decision, thus, rested on an interpretation of the federal governments
regulatory interests, which as the court observed, differ from the broad police powers
that the states enjoy to regulate the medical profession. Id.; see also Barsky, 347 U.S.
at 449. Indeed, because of this distinction between the regulatory interests of the
federal and state governments, Conant does not compel heightened scrutiny where a
state exercises its broad police powers to regulate the medical profession to protect
public health and safety, Wollschlaeger, 2014 U.S. App. LEXIS 14192, at *72, and
Caseys reasonableness test controls.
When speech occurs within the confines of a professional relationship and is
incidental to the services provided by the professional, rational basis review governs
the analysis of regulations falling at this point on the continuum. Lowe, 472 U.S. at
232; Pickup, 740 F.3d at 1228-29; Moore-King, 708 F.3d at 567-70; Bowman, 860
F.2d at 604. As the Supreme Court has emphasized, it has never been deemed an
9

abridgement of freedom of speech or press to make a course of conduct illegal merely
because the conduct was in part imitated, evidenced, or carried out by means of
language, either spoken, written, or printed. Ohralik v. Ohio State Bar Assn, 436
U.S. 447, 456 (1978); see also Coggeshall v. Mass. Bd. of Registration of
Psychologists, 604 F.3d 658, 667 (1st Cir. 2010) (Simply because speech occurs does
not exempt those who practice a profession from state regulation[.]). Thus, a
regulation of speech by professionals is not invalid, nor is it subject to [F]irst
[A]mendment strict scrutiny, merely because it restricts some kinds of speech.
Bowman, 860 F.2d at 604 (citing Ohralik, 436 U.S. at 456-57). A statute regulating a
profession is constitutional so long as any inhibition of that right is merely the
incidental effect of observing an otherwise legitimate regulation. Id. (quoting
Underhill Assoc. v. Bradshaw, 674 F.2d 293, 296 (4th Cir. 1982)).
Moreover, doctors are routinely held liable for giving negligent medical advice
to their patients, without serious suggestion that the First Amendment protects their
right to give advice that is not consistent with the accepted standard of care. Pickup,
740 F.3d at 1228. Indeed, most, if not all, medical and mental health treatments
require speech, but that fact does not give rise to a First Amendment claim when the
state bans a particular treatment. Id. at 1229 As such, the First Amendment does not
permit a physician to speak the words necessary to provide or administer [a] banned
drug or counsel a patient to rely on quack medicine. Id. at 1228-29.
10

Relying on Lowe and the principles underlying the professional speech doctrine,
courts have applied rational basis review to regulations that govern professional
speech incidental to the professionals services, such as regulations that prohibit a
form of medical treatment, Pickup, 740 F.3d at 1228-29; govern counseling activities,
Moore-King, 708 F.3d at 567-70; and restrict the use of certain terms in the work
product of unlicensed accountants, Bowman, 860 F.2d at 604. Most recently, in
Wollschlaeger, the Eleventh Circuit applied rational basis scrutiny to uphold a
regulation restricting irrelevant inquiry and record-keeping by physicians regarding
firearms as a legitimate regulation of professional conduct that had only an
incidental effect on physicians speech.
2
Wollschlaeger, 2014 U.S. App. LEXIS
14192, at *5. In doing so, the Eleventh Circuit stated that the First Amendments
protections are at their nadir . . . when the professional speaks privately, in the course
of exercising his or her professional judgment, to a person receiving the professionals

2
Based on its reading of Casey, the Dissent in Wollschlaeger argues that
intermediate scrutiny applies. 2014 U.S. App. LEXIS 14192, *132. However, the
Casey Plurality used none of the language commonly understood to impart
intermediate scrutiny analysis. Casey, 505 U.S. at 884; see, e.g., Clark v. Jeter, 486
U.S. 456, 461 (1988) (to satisfy intermediate scrutiny, a regulation must be
substantially related to an important governmental objective). On the contrary, as
the Eleventh Circuit explained, the language the Dissent cites to support this reading
is . . . directed at others issues and is set forth in the opinion before the Court turned to
its discussion of the First Amendment[.] Wollschlaeger, 2014 U.S. App. LEXIS
14192, *64 n. 16; but see Greater Balt. Ctr. for Pregnancy Concerns, Inc. v. Mayor &
Council of Balt., 683 F.3d 539, 554 (4th Cir. 2012), vacated on rehg en banc on other
grounds, 721 F.3d 264 (4th Cir. 2013) (assuming without analysis that Casey
employed intermediate scrutiny).

11

services. Wollschlaeger, 2014 U.S. App. LEXIS 14192, at *51-52; see also
Thornburg v. American College of Obstetricians & Gynecologists, 476 U.S. 747, 802
(1968) (Burger, J., dissenting) (explaining that regulations governing how physician
practices profession or dialogues physician engages in while treating patients
subject rational basis review).
While the Wollschaelger Dissent expressed a concern that the Majority lumped
all professional speech into one, unprotected category, Wollschlaeger, 2014 U.S.
App. LEXIS 14192, at *141 (Wilson, U.S.C.J., dissenting), it is unnecessary for this
Court to consider whether the Eleventh Circuits formulation is too broad. Even the
Wollschlaeger Dissent acknowledges the regulation in Pickup, which is virtually
identical to the regulation here, left only a narrow category of speech unprotected by
the First Amendment, consistent with the principles underlying the professional
speech doctrine. Id. In accordance with the Eleventh Circuits reasoning, N.J. Stat.
Ann. 45:1-54, -55 should be subject to rational basis review as it regulates only
speech that is the functional equivalent of providing a drug, like in Pickup.
Wollschlaeger, 2014 U.S. App. LEXIS 14192, at *141-42 (Wilson, U.S.C.J.,
dissenting). Therefore, the regulation at issue here, more surely than the one in
Wollschlaeger, falls within the principles underlying the professional speech doctrine
because it does not prohibit any speech other than that which is necessary and
incidental to the provision of SOCE therapy.
12

In sum, the State has a legitimate interest and concern in protecting the welfare
of its citizens, and especially minors, from dangerous and unsound medical practices
that extend beyond initial licensing requirements. Barsky, 347 U.S. at 449; Prince v.
Massachusetts, 321 U.S. 158, 166 (1944); Semler v. Oregon State Bd. of Dental
Examrs, 294 U.S. 608, 611 (1935). Due to this regulatory interest, the First
Amendments protection of professional speech is diminished where that speech
occurs within the professional relationship. Casey, 505 U.S. at 884; Pickup, 740 F.3d
at 1227-28. Therefore, when professional speech is merely incidental to the provision
of the professionals services, such as when medical treatment is carried out through
speech, the First Amendment requires only rational basis review. Ohralik, 436 U.S. at
456; Pickup, 740 F.3d at 1228-29; Moore-King, 708 F.3d at 567-70; Bowman, 860
F.2d at 604; see also Busch v. Marple Newtown Sch. Dist., 567 F.3d 89, 99 n.11 (3d
Cir. 2009) (holding that rational basis review is appropriate where First Amendment
rights not burdened).
Guided by these principles, this Court should find that N.J. Stat. Ann. 45:1-
54, -55 is subject only to rational basis review. With the enactment of the statute, the
State sought to fulfill its obligation to the protect the welfare of minors by defining the
acceptable standard of mental health care as it pertains to SOCE in New Jersey. The
statute was narrowly drawn to accomplish this end by prohibiting only the provision
of a particular mental health therapy that the State has deemed harmful to minors
13

based upon an expansive legislative inquiry. The statute does not limit state-licensed
mental health providers from engaging in the public dialogue or even prohibit them
from discussing or recommending SOCE. N.J. Stat. Ann. 45:1-54, -55. The statute,
thus, prohibits speech by professionals that is merely incidental to the valid regulation
of a medical practice. The statute, therefore, is more akin to those seen in Pickup,
Moore-King, and Bowman, and should be subject to rational basis review, which it
easily passes as explained in the Appellees principle brief.
CONCLUSION
For the foregoing reasons, this Court should affirm the District Courts Order
granting summary judgment to Defendants-Appellees.
Respectfully submitted,
JOHN J. HOFFMAN
ACTING ATTORNEY GENERAL OF NEW JERSEY

By: s/ Susan M. Scott
Susan M. Scott
Deputy Attorney General
P.O. Box 112, 25 Market Street
(609) 292-8150
NJ Bar #02897-2004

Date: August 4, 2014

14

CERTIFICATION OF BAR MEMBERSHIP

I certify that I am an attorney in good standing of the bar of the Third Circuit.
Dated: August 4, 2014 s/Susan M. Scott
Susan M. Scott
(609) 292-8150
NJ Bar #02897-2004

CERTIFICATION OF COMPLIANCE WITH RULE 32(a)

I certify that this brief complies with the typeface requirements of Fed. R. App.
P. 32(a)(5) and the type style requirements of Fed. R. App. P. 32(a)(6) because this
brief has been prepared in a monospaced typeface using Microsoft Word 2010 with 12
characters per inch in Times New Roman. I further certify that this brief complies
with the page limitation of the Court and Fed. R. App. P. 32(a)(7)(A) because this
brief does not exceed 15 pages.
Susan M. Scott
(609) 292-8150
NJ Bar #02897-2004

15

CERTIFICATION OF COMPLIANCE WITH LOCAL RULE 31.1(c)

I certify that the text of the paper copies of this brief and the text of the PDF
version of this brief filed electronically with the Court today are identical. I further
certify that prior to electronically filing this brief with the Court today it was scanned
by McAfee VirusScan Enterprise 8.7.0i, a virus detection software, and found to be
free from computer viruses.
Susan M. Scott
(609) 292-8150
NJ Bar #02897-2004

Susan Scott DOL LPS State NJ US

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