Upper Deerfield Police Shooting

Case 1:17-cv-07272-NLH-AMD Document 1-2 Filed 09/20/17 Page 1 of 50 PageID: 7
PUFF & COCKERILL, L.L.C.

By: Richard S. Kaser, Esquire
NJ Attorney ID No. 00266981
i22 Delaware Street, PO Box 684
Woodbury, New Jersey 08096
(g56) 845-ooli
Fax: (856) 845-1805
Email: rkaser@pufflaw.com
Attorneys for Plaintiffs Gerald Sykes and
Margot Sykes
GERALD SYKES and MARGOT SYKES, h/w SUPERIOR COURT OF NEW JERSEY
LAW DIVISION
Plaintiff(s), CUMBERI~AND COUNTY
vs.
DOCKET #: L-626-1~
STATE OF NEW JERSEY (its divisions,
departments, bureaus, sections, units, offices, Civil Action
agencies); JOHN/JANE DOE 1-l0
DIRECTORS, SUPERVISORS, OFFICERS,
SERVANTS, AGENTS, ASSIGNEES, SUMMONS
DELEGATES AND/OR EMPLOYEES of the
State of New Jersey; OFFICE OF THE
ATTORNEY GENERAL OF THE STATE OF
NEW JERSEY (its divisions, departments,
bureaus, sections, units, offices, agencies);
ANDREW B. JOHNS, individually and as
director, supervisor, officer, servant, agent,
assignee, delegate and/or employee of the
Office of the Attorney General of the State of
New Jersey; JOHN/JANE DOE 11-20
SERVANTS, AGENTS, ASSIGNEES,
New Jersey; STATE OF NEW JERSEY OFFICE
OF INFORMATION TECHNOLOGY (its
divisions, departments, bureaus, sections,
units, offices, agencies); DAVID WEINSTEIN,
individually and as director, supervisor, officer,
servant, agent, assignee, delegate and/or
employee of the State of New Jersey Office of
Information Technology; CRAIG REINER,
Information Technology; JOHN/JANE DOE
2i-3o DIRECTORS, SUPERVISORS,
OFFICERS, SERVANTS, AGENTS,
ASSIGNEES, DELEGATES AND/OR
EMPLOYEES of the State of New Jersey Office
of Information Technology; STATE OF NEW
JERSEY OFFICE OF EMERGENCY
MANAGEMENT (its divisions, departments,

JOHN/JANE DOE 3i-4o DIRECTORS,
SUPERVISORS, OFFICERS, SERVANTS,
AGENTS, ASSIGNEES, DELEGATES AND/OR
of Emergency Management; EDWARD
CONROW, individually and as director,
supervisor, officer, servant, agent, assignee,
delegate and/or employee of the State of New
Jersey Office of Emergency Management
and/or the County of Cumberland; JENNIFER
LICHTENSTEIN, individually and as director,
Jersey Office of Information Technology and/or
the County of Cumberland; NEW JERSEY
STATE POLICE (its divisions, departments,
bureaus, sections, units, offices, agencies,
directors, supervisors, officers, servants, agents,
assignees, delegates and/or employees);
JOHN/JANE DOE 41-ioo NEW JERSEY
STATE POLICE TROOPERS, in their individual
and official capacities (names being fictitious
with some bearing badge numbers, including
but not limited to, ~896,7939~ 7479 7735 7622
7542, 7737 7g27~ 78i3~ 7912, X802, X822, 7913,
7758, 7622, 7343, 5637, 536i, 7913 5g97~
7434); SGT. DAVID J. PETERSEN, individually
and as director, supervisor, officer, servant,
agent, assignee, delegate and/or employee of
the New Jersey State Police; JOHN/JANE DOE
ioi-i2o COMMANDERS, MAJORS,
LIEUTENANTS, SERGEANTS, CHIEFS
AND/OR SUPERVISORS of the New Jersey
State Police; NEW JERSEY STATE POLICE
EMERGENCY MANAGEMENT SECTION (its
units, offices, agencies); MICHELLE C.
WOOLSEY, individually and as director,
delegate and/or employee of the New Jersey
State Police, Emergency Management Section;
AMBER S. SWAIN, individually and as director,
ANDREA DONOFLIO, individually and as
assignee, delegate and/or employee of the New
Jersey State Police, Emergency Management
Section; JOHN/JANE DOE 121-140
DIRECTORS. SUPERVISORS. OFFICERS.
2

New Jersey State Police, Emergency
Management Section; COUNTY OF
CUMBERLAND (its divisions, departments,
CUMBERLAND COUNTY 9-1-1 EMERGENCY
COMMUNICATIONS CENTER; CHARLES
NARDELLI, individually and as director,
delegate and/or employee of the Cumberland
County 9-1-1 Emergency Communications
Center; NEWELL BRANIN, individually and as
Cumberland County g-1-1 Emergency
Communications Center; JOHN/JANE DOE
14~-15o DIRECTORS, SUPERVISORS,
EMPLOYEES of the County of Cumberland
and/or Cumberland County g-1-1 Emergency
Communications Center; CITY OF VINELAND
(its divisions, departments, bureaus, sections,
units, offices, agencies); VINELAND POLICE
DEPARTMENT g-1-~ COMMUNICATIONS
CENTER (its divisions, departments, bureaus,
sections, units, offices, agencies); ESTHER
GUZMAN, individually and as director,
delegate and/or employee of the Vineland
Police Department 9-1-1 Communications
Center; JOHN/JANE DOE 151-160
City of Vineland and/or the Vineland Police
Department g-1-1 Communications Center;
ABC 16~-1~o PUBLIC ENTITY, COMPANY,
CORPORATION AND/OR OTHER ENTITY
(yet to be identified);
Defendant(s),
ANDREW B. JOHNS
From The State of New Jersey To The Defendants) Named Above:
The plaintiff, named above, has filed a lawsuit against you in the Superior Court
of New Jersey. The complaint attached to this summons states the basis for this lawsuit.
If you dispute this complaint, you or your attorney must file a written answer or motion
3
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 the addresses of each deputy clerk of the Superior Court
is available in the Civil Division Management Office in the county listed above and
online at htt~:~/www.;~udiciarv.state.nj.usffro se/1o~~~ de~tvclerklawref.~df.) If the
complaint is one in foreclosure, then you must file your written answer or motion and
proof of service with the Clerk of the Superior Court, Hughes Justice Complex, P.O. Box
97i, Trenton, NJ 08625-0971. A filing fee payable to the Treasurer, State of New 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 plaintiff s 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 Information Statement) if you want the court to hear your
defense.
If you do not file and serve a written answer or motion within 35 days, the court
may enter a judgment against you for the relief plaintiff demands, plus interest and
costs of suit. If judgment is entered against you, the Sheriff may seize your money,
wages or property to pay all or part of the judgment.
If you cannot afford an attorney, you may call the Legal Services office in the
county where you live or the Legal Services of New Jersey Statewide Hotline at 1-888-
LSNJ-LAW (1-888-576-5529). If 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 information 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
htt~:/Jwww.judiciarv.state.ni.us/~rose~~o1~~ de~tvclerklawref.~df.
Dated: September 12, 201 ,/s/ M ~ ICI. S v~tiit~v

MICHELLE M. SMITH
Clerk of the Superior Court
Names of Defendant to Be Served: ANDREW B. JOHNS
Address of Defendant to Be Served: State of New Jersey Office of the Attorney

General, Department of Law and Public Safety, 5 Executive Campus, Suite
205, Cherry Hill, NJ 08002
D
PUFF & CUCKERILL, L.L.C.

By: Richard S. Kaser, Esquire
NJ Attorney ID No. 002661981 ~~G ~ X017
i22 Delaware Street, PO Box 684
Woodbury, New Jersey 08096 ~i~~si~? ~ ~~~,~~
{ 856) 845-0011 c~vt~. c
~9ANAGEMEf~ FFd~~
Fax: (856) 845-i8o~
Email: rkaser@pufflaw.com
Attorneys for Plaintiffs Gerald Sykes and
Margot Sykes
GERALD SYKES and MARGOT SYKES, h/w SUPERIOR COURT OF NEW JERSEY
LAW DIVTSI4N
Plainfiiffts), CUMBERLAND COUN'T'Y
vs.
DOCKET # : L- }~t fi ~~h~: ..,.' ~ ~~~ _~
STATE OF, NEW JERSEY {its divisions, ~~,~~~
departments, bureaus, sections, units, offices,
Civil Action
agencies); JOHN/JANE DOE i-10
DIRECTORS, SUPERVISORS, OFFICERS, COMPLAINT, JURY DEMANI? AND
SERVANTS, AGENTS, ASSIGNEES, DESIGNATION OF TRIAL COUNSEL
DELEGATES ,AND/OR EMPLOYEES of the
State of New Jersey; OFFICE OF THE
A'I"rORNEY GENERAL 4F THE STATE OF
NEW JERSEY (its divisions, departments,
ANDREW B. JOHNS, individually and as
New Jersey; JOHN/JANE DOE 11-20
New Jersey; STATE ~F NEW JERSEY OFFICE
OF INFORMATION TECHNOLOGY (its
units, offices, agencies); DAVID WEINSTEIN,
individually and as director., supervisor, officer,
Information Technology; CRAIG REINER,
servant, agent, assignee, delegate and/vr
Information Technology; JOHN/JANE DOE
2z-3o DIRECTORS, SUPERVISORS,
OFFICERS, SERVA~'TS, AGENTS,
of Information Technology; STATE OF NEW
JERSEY OFFICE OF EMERGENCY
MANAGEMENT (its divisions, departments,

JOHN/JANE DOE 31-4o DIRECTORS,
SUPERVISORS, OFFICERS, SERVANTS,
AGENTS, ASSIGNEES, DELEGATES A~'~tD/OR
EMPLOXEES of the State of New Jersey Office
of Emergency Management; EDWARD
CONROW, individually and as director,
Jersey Office of Emergency Management
acid/or the County of Cumberland; JENNIFER
LICHTENSTEIN, individually and as director,
Jersey Office of Information Technology and/or
the County of Cumberland; NEW JERSEY
STATE POLICE (its divisions, departments,
bureaus, sections, units, offices, agencies,
directors, supervisors, officers, servants, agents,
assignees, delegates and/or employees);
JOHN/JANE DOE 41-loo NEW JERSEY
STATE POLICE TROQPERS, in thezr individual
and official capacities (names being fictitious
with some bearing badge numbers, including
but not limited to, ~8g6,7939~ 7479, 7735 7622,
7542 7737, 7827 78i3~ 7912, 7802, X822, 7913
7758 7622 7343 5637 536i~ 7913 5g97~
7434); SGT. DAVID J. PETERSEN, individually
and as director, supervisor, officer, servant,
agent, assignee, delegate and/or employee of
the New Jersey State Police; JOHN/JANE DOE
loi-~.2o COMMANDERS, MAJORS,
LIEUTENANTS, SERGEANTS, CHIEFS
AND/QR SUPER`VISORS of the New Jersey
State Police; NEW JERSEY STATE POLICE
EMERGENCY MANAGEMENT SECTION (its
unifis, offices, agencies); MTCH~LLE C.
W~OL.SEY, individually and as director,
AMBERS. SLAIN, individually and as director,
ANDREA DONOFLIO, individually and as
assignee, delegate and/ar employee of the New
Jersey State Police, EYnergency Management
Secfiion; JOHN/JANE DOE 121-i4o
SERVAN'T'S, AGENTS, ASSIGNEES,

DELEGATES AND/OR EMPLOYEES of
the
New Jersey State Police, Emergency
Management Section; COUNTI' OF
CUMBERLAND (its divisions, departments,
CUMBERLAND CC?UN'TY 9-1-x EMERGE
NCY
COMMUNICATIONS CENTER; CHARLES
NARDELLI, individually and as director,
supervisor, ofFcer, servant, agent, assignee,
delegate and/or employee of the Cumberland
County g-1-7 Emergency Communications
Center; NEWELL BRANIN, individually and
as
director, super~~isor, officer, servant, agent,
Cumberland County g-1-1 Emergency
Communications Center; JOHN/~TANE DOE
141-15o DIRECTORS, SUPERVISORS,
EMPLOYEES of fihe County of Cumberland
and/or Cumberland County g-1-1 Emergency
Communications Center; CITY OF VINELAND
{its divisions, departments, bureaus, sections,
units, offices, agencies); VINELAND POLICE
DEPARTMENT 9-~-1 COMMUNICATIONS
CENTER (its divisions, departments, bureaus,
sections, units, offices, agencies); ESTHER
GUZMAN, individually and as dr~rectar,
delegate and/or erriployee of the Vineland
Police Department 9-1-1 Communications
Center; JOHN/JANE DOE 151-~60
City of Vineland and/or the Vineland Police
Department g-1-~ Communications Center;
ABC ibl-x~o PUBLTC ENTITY, COMPANY,
CORPORATION AND/OR ETHER ENTITY
(yet to be identified);
Defendant{s),
The Plaintiff(s), GERALD SYKES and MARGOT

SYKES, husband and wife,
individually and in his/her/their own right, currently
residing at 382 Centerton Rd., Bridgeton,
Cumberland County, New Jersey, byway of comp
laint against the above named parties, says:
I. INTRODUCTORY STATEMENT
1. This Complaint arises from the egregious, outrageous,
and unlawful acts of members
and/or employees of the STATE OF NEW JERSEY; OFFIC
E OF TI-~E ATTORNEY GENERAI~
OF THE STATE 4F NEW JERSEY; STATE OF NEV1r JERSE
Y OFFICE OF INFORMATION
TECHNOLOGY; STATE OF NEW JERSEY OFFICE OF EMER
GENCY MANAGEMENT; NEW
JERSEY STATE POLICE; NEW JERSEY STATE POLICE
EMER GENCY MANAGEMENT
SECTION; COUN'T'Y OF CUMBERLAND; CUMBERLAND COUN
TY g-1-1 EMERGENCY
COMMUNICATIONS CENTER; CI'I'Y OF VINEL~IND; VTNEL
AND POLICE DEPARTMENT 9-
1-z COMMUNICATIONS CENTER; ANDREW JOHNS; DAVID
WEINSTEIN; CRAIG REINER;
EDWARD C4NROW; JENNIFER LICHTENS'TEIN; SGT. DAVID
J. PETERSEN; MICHELLE C.
WOOLSEY; .AMBER S. SWAIN; ANDREA N. DONQFLIO;
CHARLES NARDELLI; NEWELL
BRANIN; ESTHER GUZMAN; and the following individuals and/or
entities which names are
fictitious as their true identities are unknown to date but who knew,
participated in and/or
reasonably should have known and/oz knowingly condoned and/or
covered-up the acts and/or
omissions of the above named Defendants: JOHN/JANE DOE 1-lo
DIRECTORS,
SUPERVISORS, OFFICERS, SERVANTS, AGENTS, .ASSIGNEES,
DELEGATES .AND/OR
EMPLOYEES of the State of New Jersey; JOHN'/JANE DOE 1~-2o
DIRECTORS,
', SUPERVISORS, OFFICERS, SERVANTS, AGENTS, ASSIGNEES,
DELEGATES AND/OR
EMPLOYEES of the Office of the Attorne Gener al of the Stato of New
Y JerseY; JOHN/ JANE
DOE 2x-3o DIRECTORS, SUPERVISORS, OFFICERS, SERVANTS,
AGEN'T'S, ASSIGNEES,
DELEGATES AND/DR EMPLOYEES of the State of New Jersey Office
of Information
Technology; JOHN/JANE DOE 3i-4o DIRECTORS, SUPERVISOR
S, OFFICERS, SERVANTS,
AGENTS, ASSIGNEES, DELEGATES AND/OR EMPLOYEES of the
State of New ~Tersey Office
of Emergency Management; JOHN/JANE DOE 41-loo NEW JERSEY
STATE POLICE
TRC?OPERS, including but not limited to those troopers bearing
badge numbers ~896~ 7939
7479 7735, 7622, 7542, 7737, 7g27~ 78i3~ 79 2, 7802, X822, 7913 7758,
76 2, 7343, 5 37, 53 61
7913 5$97, 7434 JOHN/JANE DOE ioz-12o COMMANDERS, MAJORS, LIEUTENANTS,
4
SERGEANTS, CHIEFS AND/OR SUPERVISORS of the New

Jersey State Police; JOHN/JAI~1E
DQE 12i-i4o DIRECTORS, SUPERVISORS, OFFICERS,
DELEGATES AND/OR EMPLOYEES of the New Jersey
State Police, Emergency Management
Section; JOHN/JANE DOE 141-i5o DIRECTORS, SUPE
RVISORS, OFFICERS, SERVANTS,
AGENTS, ASSIGNEES, DELEGATES AND/OR EMPLOYEE
S of the Caunty of Cumberland
and/or the Cumberland County 9-1-~ Emergency Comm
unications Center; JOHN/JANE DOE
151-16o DIRECTORS, SUPERVISORS, OFFICERS, SERV
ANTS, AGENTS, ASSIGNEES,
DELEGATES AND/DR EMPLOYEES of the City of Vinela
nd and/or the Vineland Police
Department 9-z-i Communications Center; and A.BC z6i-17
o PUBLIC ENTITY, COMPANY,
CORPORATION AND/OR OTHER ENTITY. Further, any
and all allegations set forth herein
shall be directed at each of them individually. P]aintiffs seek compe
nsatory and punitive
damages and other relief, pursuant to applicable state and federa
l civil rights law, specifically for
the violations of the Plaintiffs' rights, privileges and immunities
as guaranteed by the Fourth and
Fourteenth Amendments to the Constitution of the United States
and in violation of New Jersey
Civil Rights laws. The claims on behalf of the Plaintiffs, Gerald Sykes
and Margot Sykes, h/w, are
also being brought pursuant to those rights afforded the Plaintiffs
pursuant to the Constitution
of the State of New Jersey, more specifically Article I, Sections 1 and ~,
N.J.S.A. 10:6-1, et seq.,
and N.J.S.A. X9:8-i, et seq., among other common law and statutory
rights.
2. On July 2g, 2U16, at approximately r1:2~ p.m., Plaintiffs, Gerald
Sykes and Margot
Sykes, were peacefully sleeping in their home, which is situated at
the end of an approximately
quarter mile long paved driveway off of Centerton Road, Bridgeton, New
Jersey. On said date
and at said place, Mr. and Mrs. Sykes were the victims of wrongful
and illegal conduct by the
above named party Defendants.
3. At or about 11:39 p.m., several yet to be identified state police troope

rs, employed by the
New Jersey State Police, were wrongfully dispatched to the Plaintiffs'
residence as a result of a
series of grossly negligent errors by 9-1-1 telecommunicators in both the Cumb
erland County 9-
z-i Emergency Communications Center and the Vineland Police

Department 9-1-x
Communications Center.
4. The currently known employees) of the Cumberland County g-z-1

Emergency
Communications Center involved in this matter is/are: CHARLES
NARDELLI and NEWELL
BRANIN.
5. The currently Icnown employees) of the Vineland Poliee Department

9-1-~ I~
Communications Center is/are: ESI'HER GUZVIAN.
6. The aforesaid named Defendants, and others yet unknown, were grossly
negligent in
their failure to follow proper procedures, protocols and/or training in the handling
of 9-i-~.
phone calls.
~. As a result of the gross negligence of the aforesaid call centers and their employe
es and
supervisors collectively, several yet to be identified New Jersey State Police
troopers were
ezroneously dispatched to the Plaintiffs' address under the misinformation that someone
at that
address made a g-~.-i phone call and then hung up.
I'~ 8. The yet to be identified state trooI~ ers, who are believed to be identified by badge
numbers ~8q6 and 793g, claimed to have knocked on fihe front door of the home of
Plaintiffs,
Gerald Sykes sand Margot Sykes, and after receiving no response, walked around to
the back of
the home and up onto the Sykes' deck. The yet to be identified state police troopers
peered
through the French doors of the Sykes' bedroom and saw that both Gerald Sylces and Margot
Sykes were sleeping in their bed. The police troopers failed to establish communication
with the
Sykes. T`he Sykes were awakened by their barking dog and first saw a light from a flashlight.
g. Gerald Sykes arose from the bed believing that he and his wife were about to be
burglarized and in fear far their safety and their lives. Gerald Sykes got out of
bed, retrieved a
pistol from his nightstand, and proceeded around the bed to the glass French doors
in his
bedroom. There, Mr. Sykes could see the figures of two people but did not see any identifyi
ng
characteristics, features or symUols on either figure. Mr. Sykes immediately called
out to his wife
and yelled for her to ca119-1-1. It is Mr. Sykes belief that he heard one of the
unidentified
persons on his deck state, "do not call 9-1-1; you will be charged with a
false call." Hearing those
words increased Mr. Sykes' fear and anxiety level, over and above seeing
the two unidentified
figures on his back deck. Mrs. Sykes attempted to ca119-z-1 from the
house phone and informed
her husband that the phone was dead. Whether the house phone truly
was not working or due to
the extreme fright of Mrs. Sykes, she misdialed the number, nevertheless,
the fact remains that
they both believed ghat the phone had been disabled by the two unidentified men
outside or
taken out of order, thus additionally increasing their fears and anxiety. Mr.
Sykes then departed
from the French doors in his bedroom, wearing only his boxer shorts, and
as he is leaving, he
tells his wife to call 9-i-1 on the cell phone. Mr. Sykes went to his bedroom closet
across the
room and retrieved a shotgun and continued toward the great room. Unbekno
wnst to Mr. Sykes,
the police troopers, who were still unidentified to the Sylces, left their position in front
of the
glass doors of the bedroom and moved to in front of the glass doors of the great room.
None of
the windows in the home had the shades or drapes closed for privacy due to the remotene
ss and
sec]uded location of the home. Upon seeing the flashlights from unknown persons
on his deck,
Mr. Sykes tossed his pistol to the floor and held the shotgun across his body
zn the "ready"
position.
lo. Upon Mr. Sykes entering his great room, the yet to be identified state police troopers
fired four shots from outside the home; three shots going through the glass French door
leading
from the Sykes' deck to the great room and the fourth shot through an adjoining window
and
lodging in a leathez sofa. Mr. Sykes was critically struck by three of the four shots fired.
As a
result, Mr. Sykes suffered life-threatening bullet wounds; two to his chest and one
to his upper
groin area.
1i. Due to the impact of being stzuck by three bullets, Mr. Sykes fell into a coffee table
then
onto the floor. Still believing that he and his wife were under attack, Mr. Sykes fired
one shat in
defense. Mr. Sykes retaliatory shot was fired through a sepcrate pane of glass of
the French
doors leading out to the deck. The shot, which was only birdshot, was fired in the heat
of the
7
moment and was directed toward the adjoining French door. Mr. Sykes
was hoping to scare off
the unlcnown intruders.
iz. After the yet to be identified state police troopers shot Mr. Sikes, they
retreated to their
vehicles rather than attempting to render aid or establish any communications
with either Mr.
or Mrs. Sykes. Upon being critically injured, Mr. Sykes managed to get back
to his bedrooi7l.
From there, he called 9-1-1 and advised them that he had been shot by two
men who he believed
to be "prowlers."
i3. Although Mr. Sykes promptly called emergency services and pleaded with them
far the
aid of the police and life-saving emergency personnel, he spent nearly forty-five
minutes on the
phone with various g-1-~. telecommunicators, pleading for help all the while bleeding
profi~sely
from the three C3) bullet holes in his torso.
x4. The delay in police and/or emergency care was due solely to the lack of proper
communications between the various 9-1-1 telecommunicators, supervisors, and the New
Jersey
State Police personnel involved. Throughout the above time frame, Mrs. Sykes was attemptin
g
to render aid to her husband who she believed was dying. Mrs. Sykes was following all
commands given to her husband by the various g-1-1 telecommunicators and/or superviso
rs.
15. Although Mr. Sykes lay in his bed in desperafie need of emergency care, he was f rst
instructed by the 9-1-1 telecommunicators to lay still in his bed, then later instructed to get
up
out of bed and walk through his home and out the front door before he would receive any
medical attention. Mr. Sykes could only walk with the aid of his 8o year old wife. Once outside
the front door of his home, Mr. Sykes was ordered by the state police to lay face down in 11is
yard. Despite the three bullet-hole wounds, external bleeding and his pleading for the police
to
arrive, Mr. Sykes was placed under arrest and handcuffed with his hands restrained behind
his
back.
i6. Mrs. Sykes was also placed under arrest and/or unlawful restraint in that she was
ordered into a state police vehicle and taken against her will to the state police barracks in
Bridgeton, New Jersey. Mrs. Sykes remained against her will in the Bridgeton Station ba~~acks
for three to four hours being interrogated without the benefit

of counsel and without being
advised of the condition of her husband.
1~. Mr. Sykes was flown by helicopter to Cooper Hospital where

he was admitted in critical
condition. Fortunately, Mr. Sykes survived the extensive
injuries sustained, which include, but
are not limited to, a collapsed lung, broken ribs, lass of spleen,
perforation of his bowel,
muscular and tissue damage, injuries to his left wrist, and emotio
nal and psychological
damages. Mrs. Sykes suffers fzom emotional and psychological
injuries.
18. The actions of all Defendants, as described above, were negligent,
malicious, willful,
wanton, intenfiional, grossly negligent and undertaken in bad
faith. As a result of the aforesaid
actions, Mr. Sykes suffered severe and painful bodily injuries which
necessitated obtaining
medical treatment. The injuries sustained and medical treatment require
d caused Mr. Sykes
great pain and suffering, will continue to cause him great pain and
suffering, incapacitate him
from pursuing his usual activities, and have left him with perma
nent disabilities and permanent
doss of bodily function and will in the fitture similarly incapacitate him,
cause him great pain and
suffering and require future medical treatment. In addition, Mr. Sykes
was forced to incur
and/or will incur great expenses for his medical care.
x9. On the above dates and as a result of the above cited incident, Mrs. Sykes
was the victim
of wrongful and illegal conduct of the above named Defendants. Mrs,
Sykes was caused to
witness the shooting of her husband and its prolonged aftez~math,
includi ng but not limited to,
witnessing the suffering of her husband for an extended period. Conseq
uently, Mrs. Sykes
suffers great psychological and emotional distress as a result of the aforesa
id incident in
witnessing her husband's pain and suffering and due to her own unlawf
ul restraint as she was
prohibited from going to the hospital to be with her husband who she though
t was dying and
was kept fiom knowing his condition.
20. Mrs. Sykes was further traumatized by the New Jersey State Police as they
ordered her
into a state police vehicle, transported her to the state police barracks and
held her at the
Bridgeton Station barracks for several hours. Compounding the unlawf
ul restraint, Mrs. Sykes
9
was dressed only in her nightgown, as she was sleeping prior to

the unlawful intrusion into their
residence by the state police. The New Jersey State Police refused
to permit Mrs. Sykes to put on
appropriate clothing and footwear prior to being forcibly taken
from her husband and her
property. She was interrogated by the New Jersey State Police
in such a vulnerable condition.
II. PARTIES
21. Plaintiff, GERALD SYKES, is an adult individual residing at 382 Centerto
n Rd.,
Bridgeton, New Jersey. At the time of the above incident, Mr. Sykes was
~6 years of age and in
very govd health. At all times relevant to this Complaint, Mr. Sykes
was lawfully at his residence.
22. Plaintiff, MARGOT W. SYKES, is an adult individual residing at 382 Centerto
n Rd.,
Bridgeton, New Jersey. At the tune of the above incident, Mrs. Sykes was
8o years of age and in
very good health. At all times relevant to this Complaint, Mrs. Sykes was
lawfully at her
residence.
23. Defendant, STATE OF NEW JERSEY (unless otherwise noted, refers to and
includes, but
is not limited to for liability purposes, its divisions, departments, bureaus, sections
, units,
offices, agencies), is a government agency or body politic with an address of: 25 Market
St., PO
Box o$o, Trenton, NJ, and is responsible for, among other things, protecting the civil
rights of
the citizens' of the state, the development and operation of the 9-~.-1 Emergency
Communications Centers throughout the state of New Jersey and the
hiring/employment/supervision of all personnel of the New Jersey State Police.
24. Defendant, OFFICE OF THE ATTORNEY GENERAL OF THE STATE OF NEW JERSEY
(unless otherwise noted, refers to and includes, but is not limited to for liability purpose
s, its
divisions, departments, bureaus, sections, units, offices, a~encies~, is a governmenfi
agency or
', body politic with an address of 25 Market St., PO Box o80, Trenton, NJ, and is responsi
ble for,
among other things, protecting the civil rights of the citizens' of the state, the developm
ent and
operation of the g-x-1 Emergency Communications Centers throughout the state of New Jersey
and the hiring/employment/supervision of all personnel of the New Jersey State Police.
10
25. Defendant, STATE OF NEW JERSEY OFFICE OF INFORMATION TECHNOLOGY
(unless otherti~ise noted, refers to and includes, but is not limited to far liability purposes,
its
divisions, departments, bureaus, sections, units, offices, agencies), is a government agency
or
body politic with an address of 30o Riverview Plaza, PO Sox 212, Trenton, NJ, and is
responsible for, among other things, the development and operation of the 9-1-1 Emergency
Communications Centers throughout the state of New Jersey.
z6. Defendant, STATE OF NEW JERSEY OFFICE OF EMERGENCY MANAGEMENT
(unless otherwise noted, refers to and includes, but is not limited to for liability purposes, its
divisions, departments, bureaus, sections, units, offices, agencies), is a government agency or
body politic with an address of 30o Riverview Plaza, PO Box 212, Trenton, NJ, and is
responsible for, among other things, the development and operation of fine g-~.-X Emergency
Communications Centers throughout the state of New Jersey.
2~. Defendant, NEW JERSEY STATE POLICE (hereinafter referred to as NJSP) (unless
otherwise noted, refers to and includes, but is not limited to for liability purposes, its divisions,
departments, bureaus, sections, units, offices, agencies), is a government agency or body politic
with an address of: PO Box X06$, River Rd., West Trenton, NJ and having barracks located at:
Bridgeton Station, 1 Landis Ave., Bridgeton, NJ; Buena Vista Headquarters, X045 Route
54~
Williamstown, NJ, and other locations throughout the state of New Jersey. The NJSP is part of
the government of the State of New Jersey and is responsible for, among other things, providing
emergency communications and police services fihroughout the state, including the address of
the Plaintiffs hea-ein.
28. Defendant, NEW JERSEY STATE POLICE EMERGEI~TCY MANAGEMENT SECTION
(unless otherwise noted, refers to and includes, but is nofi limited to for liability purposes, its
divisions, departments, bureaus, sections, units, offices, agencies), is a government agency or
body politic with an address of PO Box X068, River Rd., West Trenton, NJ and is responsible
foz, among other things, organizing, directing, staffing, coordinating and reporting the activities
of the bureaus which make up the Emergency Manageinenl Section, including but not limited to
11
the Communications Bureau which processes the New

~Tersey State Police emergency, non-
emergency and 9-i-i phone calls.
29. Defendant, COUNTY OF CUMBERLAND, is a govern

ment agency or a body politic with
offices at 6o W. Broad St., Bridgeton, NJ.
30. Defendant, CUMBERLAND COUNTY ~-i-x EMERGENCY

COMMtJNICATiONS
CEN'T'ER, with offices at 63'7 Bridgeton Ave., Bridgeton, NJ,
is a department of the County of
Cumberland, State of New Jersey, and is responsible for provid
ing 9-1-i emergency
communication services for the residents of Cumberland County
, with the exception of Vineland
City.
3i. Defendant, CITY OF VTNELAND, is a government agency or

a body politic with offices at
64o E. Wood St., Vineland, NJ.
32. Defendant, VINELAND POLICE DEPARTMENT g-i-~. COMML7NIC

ATIONS CENTER,
with offices located at 11z N. Si~~th St. Vineland, NJ, is a depart
ment of the City of Vineland,
State of New Jersey, and is responsible for providing 9-z-~ emerg
ency communication services
for City of Vineland residents.
33 Defendant, ANDRE4~r B. JOHNS, on July 2g, 2ox6, and dates prior

thereto and
thereafter, was employed by Defendant, State of New Jersey and/or
Office of the Attorney
General of the State of New Jersey, as Deputy Attorney General. He is
sued individually and in
IC his official capacity as an employee of the State of New Jersey
and/or Office of the Attorney
General of the State of New Jersey.
34 Defendant, DAVID WEINSTEIN, on July 2g, 2oz6, and dates prior

thereto and
thereafter, was employed by Defendant, State of Ne~v Jersey and/or
State of New Jersey Office
of Information Technology, as the Chief Technology Officer. He is sued
indi~~idually and in his
official capacity as an employee of the State of New Jersey and/or State
of New Jersey Office of
Information Technology.
35 Defendant, CR.A.TG REINER, on July 2g, 2oi6, and dates prior thereto
and thereaftez,
was employed by Defendant, State of New Jersey and/or State of New
Jersey Office of
12
Information Technology, as Director, Office of Emergency Telecom

munications Services. He is
sued individually and in his official capacity as an employee of the State
of New Jersey and/or
State of New Jersey Office of Information Technology.
36. Defendant, EDWARD CONROW, on July 29, 2016, and dates prior
thereto and
thereafter, was employed by Defendant, State of New Jersey and/or
of Emergency Management and/or the County of Cumberland, as Directo
r of Emergency
Services Cumberland County, County Office of Emergency Management
Coordinator. He is sued
individually and in his official capacity as an employee of the State of New
Jersey and/or State of
New Jersey Off~.ce of Emergency Management and/or the County of Cumber
land.
37. Defendant, JENNIFER LICHTENSTEIN, on July 2g, 2oz6, and dakes prior
thereto and
thereafter, was employed by Defendant, State of New Jersey and/or State
of New Jersey Office
of emergency Management and/or the County of Cumberland, as the g-1-i County
Coordinator.
She is sued individually and in her official capacity as an employee of the
State of Ne~v Jersey
and/or State of New Jersey Office of Emergency Management and/or the County
of
Cumberland.
38. Defendant, SGT. DAVID J. PETERSEN, on July 29, zo16, and dates prior
thereto and
thereafter, was employed by Defendant, State of New Jersey and/or NJSP, as
a sergeant of the
New Jersey State Police, Bridgeton Station. He is sued individua]ly and in his
official capacity as
an employee of the State of New Jersey and/or NJSP.
39 Defendant, MICHELLE C. WOOLSEY, on July 2g, 2016, and dates prior thereto
and
thereafter, was employed by Defendant, State of New Jersey and/or NJSP and/or
New Jersey
State Police Emergency Management Section, as a Public Safety Telecommunicat
or. She is sued
individually and in her official capacity as an employee of the State of New
Jersey and/or NJSP
and/or New Jersey State Police Emergency Management Section.
40. Defendant, AMBER S. SWAIN, on July 29, 20 6, and dates prior thereto and thereaft
er,
was employed by Defendant, State of New Jersey andJor NJSP and/or New Jersey
State Police
Emez-gency Management Section, as a Public Safety Telecommunicator.
She is sued individually
13
and in her official capacity as an employee of the State of New

Jersey and/or NJSY and/or New
Jersey State Police Emergency Management Section.
41. Defendant, ANDREA DONOFLIO, on July 29, 2oi6, and dates

prior thereto and
thereafter, was employed by Defendant, State of New Jersey
and/or NJSP and/or New Jersey
State Police Emergency Management Section, as a Public Safety
Telecommunicator. She is stied
individually and in her o~'ficial capacity as an employee of the
State of New Jersey and/or NJSP
and/o~ New Jersey State Police Emergency Management Section.
42. Defendant, CHARLES NARDELLI, on July 29, 2016, and dates prior
thereto and
thereafter, was employed by Defendant, County of Cumberland and/or
the Cumberland County
9-1-1 Emezgency Communications Center, as Supervising Public Safety Telecom
municator. He
is sued individually and in his official capacity as an employee of the
County of Cumberland
and/or the Cumberland County 9-1-~ Emergency Communications Center.
43 Defendant, NEWELL BRANIN, on July 2g, 2016, and dates prior thereto
and thereafter,
was employed by Defendant, County of Cumberland and/or the Cumbe
rland Counfiy 9-1-i
Emergency Communications Center, as Senior Public Safety Telecc~mmunic
ator. He is sued
individually and in his official capacity as an employee of the County of Cumbe
rland and/or the
Cumberland County 9-x-i Emergency Communications Center.
44 Defendant, ESTHER GUZMAN, on July 2g, 2016, and dates prior thereto and
thereafter,
was employed by Defendant, City of Vineland and/or the Vineland Police Depart
ment g-z-~.
Communications Center, as Public Safety Telecommunicator and is sued individ
ually and in her
official capacity as an employee of the City of Vineland and/or the Vineland
Police Department
g-x-1 Communications Center.
III. 1~GENCY ALLEGATIONS
45 At all relevant times herein mentioned, the Defendants were agents, principals,
employees, servants, pai-~ners, joint ventures, and representatives of each other,

and in doing
the acts herein alleged, weze acting within the scope and course of their authority
as such agents,
14
principals, employees, servants, partners, joint ventures, and represen

tatives, and were acting
wifih the permission and consent of the other co -Defendants.
N. FACTUAL ALLEGATIONS
4b. At all relevant times, Plaintiffs, Gerald Sylces and Margot Sykes, husband
and wife,
lawfully reside at 382 Centerton Rd., Bridgeton, New Jersey.
4~. On July z9, 2oi6, the Sykes enjoyed a typical evening in their home
and went to bed for
the night around 9:3o p.m.
48. It was customary for the Sykes to leave all of the window treatments on their
windows in
the home open as well as leaving open the drapes on the full paneled glass French
doors leading
from their bedroom to their back deck and the full paneled glass French doors leading
from their
great room to their back deck. Their home is located approximately nne-quarter
of a mile back
from the road and is not visible from any other residence in the area.
49. On July 2g, 2oi6, on or about 11:25 p.m., a call came into the Cumberland County
g-i-~
Emergency Communications Center.
50. Upon information and belief, the aforesaid call was received and handled by Senior
Public Safety Telecommunicator, Newell Branin (hereinafter referred to as BRANIN

). The call
was made by someone identifying himself as Derek Howard, or some similaz name.
The caller
identified his location as being 143 Piercetown Rd., which Branin identified as being in the
Fairfield Township section of Cumberland County.
~1. .After speaking with the caller for several minutes, Branin advises the caller that he will
transfer his call to the state police.
52. As Branin attempts to reach the State Police Operational Dispatch Unit -South, which is
the stag police's 9-~-1 call and dispatch center for that surrounding location, Branin mistake
nly
calls the Vineland Police Department g-1-i Communications Center. Realizing his error, Branin
immediately disconnects the call and then correctly. calls the state police's dispatch center,
53. The call is then handed off to the state police's 9-z-i call center, and Branin disconnects
himself from said call.

15
54 Contrary to written policy, neither Branin nor his superv

isor contacted the Vineland
Police Department or their 9-1-1 Communications
Center to advise them that a call was
mistakenly sent to the Vineland 9-1-1 Communications
Center and that they should therefore
disregard that call.
55 The call that was initially and mistakenly transferred by Branin

to the Vineland Police
Department g-1-~ Communications Center was received,
based upon information and belief, by
Public Safety Telecommunicator, Esther Guzman (hereinafter
referred to as GUZMAN).
Guzman failed to follow proper procedures and protocol,
and contacted the NJSP barracks in
Bridgeton, New Jersey.
56. Guzman advised, based on information and belief, Sgt. David

J. Petersen (hereinafter
referred to as PETERSEN) of the NJSP, Eridgeton barracks, that
the Vineland Police
Department g-1-1 Communications Center received a 9-x-1
call which was a hang up. Guzman
additionally advised Petersen that she called the number back
and no one answered, so she lift a
message. Guzman further advised Petersen that the phone numb
er of the 9-x-i caller was 26~-
8747
57. Guzman then advised Petersen that the address of the caller
was 382 Centerton Rd.,
Bridgeton, New Jersey. Guzman knew or should have known that
any call originating from
Centerton Road, Bridgeton, New Jersey, would have automatically
gone to the Cumberland
'i County g-~-1 Emergency Communications Center and not to the
Vineland Police Department
g-1-1 Communications Center because the Vineland Police Depar
tment g-i-1 Communications
Center is configured to handle only calls originating from within
the City of Vineland.
58. Neither Defendant Guzman, nor Defendant Petersen, or any other
public safety
telecommunicator, operator or any other state police personnel, verifie
d the phone number w=ith
the address prior to dispatching state police troopers to the 382
Centerton Road address.
5g. Upon arrival at the Sykes' residence, although the property
was quiet and no lights were
on, the troopers did not make any attempt to call the residence nor
to the call the number given
~~
to them from Guzman. The state police troopers did not

even bother to ring the doorbell of the
Sykes' residence.
60. The uncovered windows and doors gave the state police troope
rs a clear view into and
through the entire home.
6~. Even though the state police tz~oopers could see through the
home from the front
windows, the troopers made the decision to walk around to the
back of the residence and up
onto the Plaintiffs' deck. Upon entering the deck, fihe troopers
would have been looking directly
into the great room of the home before reaching the French doors of
the Sykes' bedroom.
62. The two troopers proceeded to their right along the deck and were
then looking directly
into the Sykes' master bedroom through the double full clear glass
French doors. The troopers
could see the elderly couple, Mr. and Mrs. Sykes, sleeping in their bed
along with their dog. The
troopers saw Mrs. Sykes get out of bed and turn on a bedside light. Both
troopers could hear the
Plaintiffs' dvg barking inside the residence. Mr. Sykes would have
also been visible to the
troopers when he arose out of bed. The troopers claimed to have tried to establis
h
communication with Mrs. Sykes through the door. Mr. and Mrs. Sykes
were extremely startled
and afraid by the light and shadows emanating from their deck by unknow
n persons only feet
from their bed.
b3. The state police troopers, rather than remaining at the bedroom French doors
and
establish communication with Mrs. Sykes to make certain that Mrs. Sykes
was aware that the
unknown bodies on the deck around 1~.:4o at night were state police trooper
s and not criminals,
they chose to leave that area and walk back down the deck to be in front of the
doubly French
doors of the great room.
I~ 64. Upon Mr. Sykes walking into the great zoom with his shotgun across his
chest in the
"ready" position, he was shot at four times by the state police troopers and
struck three times,
twice in the chest and once in his groin region.
b5. As Mr. Sykes fell onto his coffee table, now more than eves in Fear for his life
and pending
burglary, he fired one shot from his shotgun through the adjacent glass door.
17
66. The police troopers radioed to their headquarters at z~.:45:0

~ p.m. that shots had been
fired.
67. Even though fihe police troopers knew that Gerald Sykes was
struck with the bullets from
the 9mm service handgun and saw Mr. Sykes laying on
the floor subsequent to the shots fired at
him, they made no afitempt to render aid to the ~6 year
oId roan. Rather, the state police
troopers left Mr. Sykes bleeding on the floor of his home and
retreated to theix vehicles.
68. One of the troopers at the residence allegedly sustained a slight
graze injury to his left
elbow as a result of either flying glass or a pellet from the bird
shot from Mr. Sykes' shotgun.
With Mr. Sykes still laying in a pool of blood on the floor of
his residence, t11e troopers drove
down the quarter mile driveway to the road and waited for other
officers to arrive. Again the
troopers made absolutely nn attempt to make contact with the
Sykes residence or to call the
phone number that was given by the Vineland Police Department
y-i-1 Communications Cente~~.
69. The two troopers transmitted over their radios that one of the
troopers was shot but did
not disclose that they startled and awoken Mr. and Mrs. Sykes from
their bed, nor did they
broadcast that the troopers were the ones to fire first and that they
fired through the glass door
of the home, severely injuting one of the homeowners.
~o. As a result of the troopers' wanton and willful acts of failing to proper
ly assess the scene,
failing to ensure visual and audible contact between themselves and
the Plaintiffs and failing to
properly notify their superiors of the true situation, Mr. Sykes
was caused to lay in his home,
fighting death, for approximately 45 minufies, with three open bullet
wounds.
~1. After the trooper shot Mr. Sykes, it was Mr. Sykes who called g-1-x
and reported that
"growlers" were on his deck and shot him. At no time during the
4S minute ordeal while Mr.
Sykes was fighting to survive with the aid of his hysterical and frightened
wife, did either the
state police or the 9-~.-~ dispatchers with which Mi.Sykes was commu
nicating, notify him that it
was in fact two state police troopers and not "prowlers" that shot
him.
~~. The state police 9-~-1 who, upon information and belief, was Michelle
C. Woolsey, vas
I~, communicating directly with Mr. Sykes and the responding state police
troopers.
I 18
73. At no time during the 4~ minute tune frame when Mr. Sykes lie
bleeding profusely from
three gunshot wounds to his torso did the 9-x-i state police
telecommunicator advise the state
police troopers on the scene that Mr. Sykes believed that he was
shot by prowlers and that he
was pleading for the 9-~-x telecommunicator to send the police
and an ambulance. Additionally,
the state police g-i-x telecommunicator chose not to notify the state
police on the scene that D~Ir.
Sykes and Mrs. Sykes were very cooperative and were doing everything
that was asked of them.
74. Miraculously, Mr. Sykes was able to make it to his bedroom to lay down
on the bed, and
his wife applied pressure to his wounds with a towel. Mr. Sykes informe
d the 9-~.-1
telecommunicator that his gun was by his side because he and his wife
were still afraid that the
"prowlers" might gain entry into their house. Mr. and Mrs. Sykes still did
not know that the
unidentified persons and shooters were New Jersey State Police troopers. Moreove
r, as Mr. and
Mrs. Sykes waited approximately 45 minutes for the ambulance to arrive and
provide life-saving
emergency medical services to Mr. Sykes, at no time were they told that it was
a New Jersey
State Police officer that shot Mr. Sykes and that the sfiate police were sitting
idle at the enc~ of the
Sykes' driveway.
~5. The state police 9-1-z telecommunicator advised Mr. Sykes to have Mrs. Sykes
take the
gun and place it outside. Mr. Sykes wanted to unload the gun before he gave it to his
wife as she
was inexperienced with handling guns. T`hc 9-i-x telecommunicator instructed Mr.
Sykes not to
by and unload the gun due to his extreme medical condition.
~6. Rather than the state police 9-~.-1 telecommunicatoz communicate to the police troopers
on the scene that Mr. Sykes wanted to unload his shotgun and give it to his wife
to take outside,
the state police were notified that Mr. Sykes was in his bedroom with his gun next
to him.
~~. The false, misleading and incomplete information conveyed to the state police caused
the
state police to delay rendering aid to Mr. Sykes. These actions and inactions caused
additional
!, and unnecessary pain, suffering and emotional distress to both Mr. and Mrs. Sylc~s.
~ ~8. Mr. Sykes was originally informed by the state police 9-1-1 telecommunicator to remain
still in his bed. However, due to the negligence, gross negligence and willful and wanton
19
misconduct of the state police 9-x-1 telecommunicatorfoilm

g to properly communicate ~~ith the
state police on the scene, Mr. Sykes was later instructed
to get out of bed and walk through his
house to the front door and outside onto the front lawn. Mr.
Sykes, in great pain, agony and
anguish, with the aid of his frightened and hysterical 8o year
old wife, staggered to the front
door of their home. Mrs. Sykes was not permitted to assist
Mr. Sylzes down the front porch steps
and into the front yard. Mr. Sykes was ordered to make that
journey under his own power,
which, miraculously, he was able to da. Mr. Sykes, once on the
lawn, collapsed and fell to the
ground and onto his back. Mr. Sykes was then ordered by a yet
to be identified police trooper, to
roll over onto his stomach. Mr. Sykes stated that he could not do
so as he was severely injured.
1'he yet to be identified trooper grabbed Mr. Sykes and flipped him
over onto his stomach and
blood gushed out of the three bullet wounds in his body. Mr. Sykes was
then handcuffed behind
his back and remained there until the EMTs were permitted to drive
up the driveway and render
emergency first aid, stating in their report the "large amount of blood
noted around patient."
79 Il was only after the 45 minutes of Mr. Sykes pleading for the police and
an ambulance,
and him fully cooperating and doing everything he was instructed
to do and having to stagger
through his home while severely injured to make it outside and be handcu
ffed in his front yard,
was it then that the EMTs were permitted to drive the quarter mile up
his driveway to allow
them to render emergency life-saving aid to Mr. Sykes.
80. While Mr. Sykes was evacuated to Cooper Trauma Center by a medical
helicopter, where
he had to undergo life-sa~~ing emergency surgery, Mrs. Sykes was ordere
d to go with the state
police to the state police barracks in Bridgeton. Mrs. Sykes was placed in
the back of a state
police vehicle without permission to change out of her nightgown or to even
have a trooper go in
her home to retrieve appropriate clothing or even a bathrobe.
81. The state police continued to compound their negligence, gross negligence
and willful
and wanton conduct by holding Mrs. Sylc~s against her will at the state police
barracks for a
~ great deal of time without anyone talking to her ar explaining what was going
on or even
i, updating her on the condition of her husband. Mrs. Sykes was eventually
interro gated by the
20
state police while in her understandaUly extreme emotional distress

and anguish. At no time
while Mrs. Sykes was in the custody of the state police did
they advise her whether Mr. Sykes,
her husband, was alive or dead. Qnce Mrs. Sykes was released from
the police's interrogation,
she was advised that she was not permitted to go to the hospital
to be with her husband and that
he was being guarded by a state police trooper. Mr. Sykes' two
daughters drove to Cooper
Hospital at 2 a.m. to try and ascertain if their father was alive or dead.
They were refused entry
into the hospital; no police trooper or securifiy guard would inform them
of Mr. Sykes condition,
and they were told they had to wait outside in downtown Camden. They then
returned home at
4:0o a.m. where they made several phone calls to Cooper Hospital and Sgt. Peterse
n. Finally at
approximately 6:3o a.m., Sgt. Petersen informed them that the hold had been
lifted and they
were free to visit. At approximately 7:3o a.m., they were admitted entry.
82. It was n.ot until the morning of July 3oth that Mrs. Sykes was informed that
her husband
had survived through the surgery, that the "hold" was lifted on Mr.
Sykes and family members
were allowed to visit.
COUNT ONE
New Jersev Civil Rights Act
83. The preceding paragraphs i-8z are incorporated by reference as if set forth at length
herein.
84. The Plaintiffs' substantive due process and equal protection rights were violated by the
Defendants, individually and jointly, in their wilful indifference for the safety and well-bei
ng of
the Plaintiffs.
85. As a direct and proximate result of the Defendants' violations of the New Jersey
Civil
Rights Act, the Plaintiffs, Gerald Sylces and Margot Sykes, sustained temporary
and permanent
personal injuries, economic loss, shame, ridicule, severe emotional damages, psychol
ogical
damages, loss ofself-worth, loss of a vital organ, as well as other physical and psychological
damages.
21
WHEREFORE, the Plaintiffs, Gez ald Sykes and Margo

t Sykes, demand judgment
against the Defendants, individually and jointly, for compe
nsatory and punitive damages and
attorney's fees, together with interest and costs of suit, and
any other such relief this Court
deems equitable and just.
couNT ~rwo
Civil Rights Cons~iracX
86. The preceding paragraphs 1-85 are incorporated by referen

ce as if set forth at length
herein.
8~. All Defendants named herein above, acting under color of

state ]aw, conspired with each
other, reached a mutual undersfianding, and acted to undertake a
course of conduct to cover-up
the true nature of the incident and to injure, oppress, threate
n, and intimidate Plaintiffs Gerald
and Margot Sykes in their free exercise and enjoyment of
the rights and privileges and equal
protection of the law secured to them by the United States Const
itution, including the right to Ue
free from the excessive and unreasonable use of force; the right to
be free from the delay and
denial of medical attention; the right to be free from unnecessary and
wanton infliction of pain;
and the right not to be deprived of their liberty without due proces
s of la~v.
88. The Defendants took numerous overt steps in furtherance of such
conspiracy as set forth
above.
8g. As a direct and proximate result of the Defendants misconduct

and abuse of authority
detailed above, the Plaintiffs Gerald Sykes and Margot Sykes, sustain
ed the damages
hereinbefore alleged.
WHEREFORE, the Plaintiffs, Gerald Sykes and Margot Sylces, deman

d judgment
against the Defendants, individually end jointly, for compensatory
and punitive damages and
attorney's fees, together with interesfi and costs of suit, and any othez
such relief this Court
Zz
COUNT THREE
Pattern and Practice

go. The preceding paragraphs 1-89 are incorporated by referen
herein.
9x. The use of excessive force used on Mr. Sykes and the restra
int of liberties imposed upon
Mrs. Sykes by the yet to be identified state police troopers
at the Sykes' residence, and the
subsequent cover-up of the incident by the NJSP and the
state police g-i-~ telecommunicators,
along with members of the state police department (whose
identities are currently unknown)
and sanctioned by the State of New Jersey, were not isolate
d or aberrational incidents. These
actions were the direct result of systemic deficiencies in the trainin
g, supervision and discipline
of the state police troopers and the stafie police 9-~.-~ telecominunica
tors including the
indi~~idually named Defendants that began long before the wrong
ful acts committed against Mr.
and Mrs. Sykes, and these deficiencies continue to this day.
Defendants, NJSP and their
Bridgeton Barracks along with the State police g-1-z communicat
ions center, have developed,
implemented, enforced, encouraged and sanctioned a de facto
policy, practice and/ar custom of
the use of unreasonable and excessive force on citizens and cover-
up of these incidents.
92. Members of the NJSP and state police troopers employed by Defend
ant NJSP and the
state police 9-~-1 telecommunicators and supervisors, have a system
atic and documented
history of aggressive police practices, including falsifying reports
, sham internal affairs
investigations, engaging in cover-ups, unlawful azrests, malicznus
prosecution, and the use of
excessive force against the public.
93 There have been numerous complaints of civil rights violations, includ

ing the use of
excessive force, false arrest and malicious prosecution, fi]ed agains
t Defendants State of New
Jersey and the NJSP and its troopers.
94 Defendants, collectively and individually, while acting under the

color of law, engaged in
conduct that constituted a custom, policy, usage, practice, procedure or
rule of the Defendants
23
and its state police and g-1-i emergency personnel, which

is forbidden by the New Jersey State
Constitution.
95 The aforementioned customs, policies, usages, practices,

procedures and/or rules of the
Defendants individually and collectively, included the excess
ive use of force and depravation of
medical treatment of the Plaintiff, Gerald Sykes, the unlawful
detainer and mistreatment and
maltreatment of Plaintiff, Margot Sykes, as well as other innoce
nt citizens, conspiracy to deprive
the Plaintiffs of their civil rights, creation of false reports, withho
lding of evidence and cover-up.
g6. Defendants, State of New Jersey, Office of the Attorney Genera
l of the State of New
Jersey, State of New Jersey Office of Information Technology,
State of New Jersey Office of
Emergency Management, NJSP, New Jersey State Police Emerg
ency Management Section,
County of Cumberland, Cumberland County 9-1-i Emergency Comm
unications Center, City of
Vineland and Vineland Police Departmenfi q-1-1 Communicati
ons Center, by and through their
directors, supervisors, officers, servants, agents, assignees, delegat
es and/or employees,
engaged in a policy, custom and practice of inadequate screening,
hiring, retaining, training and
supervising its employees, which was the moving force behind the violatio
ns of the Plaintiffs,
Gerald Sykes' and Margot Sykes' rights described herein.
97. As a result of the directors, supervisors, officers, servants, agents, assigne

es, delegates
and/or employees of Defendants State of New Jersey, Office of the
Attorney General of the State
of New Jersey, State of New Jersey Office of Information Technology,
I' of Emergency Management, NJSP, New Jersey State Police Emergency
Management Section,
County of Cumberland, Cumberland County 9-1-1 Emergency Communicati
ons Center, City of
Vineland and Vineland Police Department 9-1-i Communications
Center, failure to properly
screen, hire, retain, train, supervise and discipline their employees, Defend
ants explicitly and
implicitly authorized, ratified and condoned the actions and illegal
conduct of the 9-i-i
telecommunicatozs, the state police troopers and their supervisory
officers identified in this
Complaint, and those not yet known or identified, and have been deliberately
indifferent to the
acts and conduct complained of herein.
24
98. The foregoing customs, policies, usages, practices, proced

ures and rules constitute
deliberate indifference to the safety, well-being and state
constitutional rights of the Plaintiffs,
Gerald Sykes and Margot Sykes, and were the direct and
proximate cause and the moving force
of the constitutional violations suffered by the aforesaid Plainti
ffs.
99~ Defendants, State of New Jersey, Ofice of the Attorney Genera
l of the State of New
Jersey, State of New Jersey Office of Information Technology, State
of New Jersey Office of
Emergency Management, NJSP, New Jersey Stafie Police
Emergency Management Section, ~
County of Cumberland, Cumberland County 9-1-1 Emergency
Communications Cenfier, City of
Vineland and Vineland Police Department g-i-~ Communicati
ons CenteY, by and through their
employes, including the individually named Defendants and
unnamed Defendants yet to be
identified, provided grossly deficient training and supervision to
its police troopers and g-1-1
emergency personnel, concerning, for example, the use of excess
ive force, the proper procedures
for evaluating 9-1-1 hang-ups, non-completed and/or transfer calls,
proper procedures in
approaching a residence, pz~acedures for proper g-i-i call protocol and
other deficiencies yet fio
be disclosed. Despifie actual and/or constructive notice that the state
police troopers, those yet to
be identified and the state police g-1-i telecommunicators and superv
isors named herein were
'~, improperly trained and violated minimally accepted police and 9-1-1
emergency practices and
procedures, they were permitted to be in contact with citizens of this
state including the
Plaintiffs herein.
loo. On October 18, 2olb, a written notice of claim was served by certified
mail upon the
Defendants, and mailed to: State of New Jersey, Office of the Attorne
y General; State of New
Jersey Tort and Contract Unit; State of New Jersey Deputy Attorney Genera
l Andrew B. Johns;
State of New Jersey g-1-i County Coordinator ~Tennifer Lichtenstein; NJSP
Division
Headquarters; NJSP Office of Emergency Management Communications
Bureau; NJSP Troop A
I Commander Francis Donlan; County of Cumberland; County of Cumbe
rland 9-x-1
Communications Center; Vineland Police Department, Chief Timothy Codisp
oti; and Vineland
Police llepartment 9-1-1 Communications Center, Sergeant Christopher
Fulcher.
25
ioi. At least six (6) months have elapsed since the service of
the notice of claim, and
adjustment or payment of the claims have been neglected or
refused.
Zoe. All of the acts and omissions committed by the Defendants
described herein for which
liability is claimed or done unlawfully, maliciously, wanton
ly, recklessly, negligently and/or with
bad faith, and said acts meet all of the standards for imposition
of punitive damages.
io3. Al.l of the acts and omissions committed by Defendants .Andrew
B. Johns; David
Weinstein; Craig Reiner; Edward Conrow; Jennifer Lichtenstein;
Sgt. David J. Petersen;
Michelle C. Woolsey; Amber S. Swain; Andrea Donoflio; Charles
Nardelli; Newell Branin; Esther
Guzman; and John/Jane Doe 1-xo directors, supervisors, officers
, servants, agents, assignees,
delegates and/or erzlployees of the State of New Jersey; John/Jane
Doe 11-2o directors,
supervisors, officers, servants, agents, assignees, delegates and/or employ
ees of the Office of the
Attorney General of the State of New Jersey; .john/Jane Doe z1-3
o directors, supervisors,
officers, servants, agents, assignees, delegates and/or employees of the
Sate of New Jersey
Office of Information Technology; John/Jane Doe 3i-4o directors,
supervisors, officers,
servants, agents, assignees, delegates and/or employees of the State of New
Jersey Office of
Emergency Management; John/Jane Doe 4i-loo NJSP troopers (yet
to be identified but with
'~ some bearing badge numbers, including but not limited to
~896~ 7939 7479 7735 76 2, 7542
7737, 7gz7~ 78i3~ 79 2, X802, 7H22, 7913, 7758 7622, 7343 5637 5361>
7913 5$97, 7434);
John/Jane Doe xoi-12o commanders, majors, lieutenants, sergeants, chiefs and/or
supervisors
of the NJSP; John/Jane Does x2~-14o directors, supervisors, officers,
servants, agents,
assignees, delegates and/or employees of the New Jersey State Police Emerg
ency Management
Section, John/Jane Doe 14X-15o directors, supervisors, officers, servan
ts, agents, assignees,
delegates and/or employees of the County of Cumberland and/or Cumbe
rland C~unt}~ 9-1-z
Emergency Communications Center; and John/Jane Doe 75~:-16o directo
rs, supervisors,
officers, servants, agents, assignees, delegates and/or employees of the
City of Vineland and/or
I' the Vineland Police Department 9-~-x Communications Center, describ
ed herein for which
liability is claimed, were conducted in their individual and official capacit
ies.
26
WI3EREFORE, the Plaintiffs, Gerald Sykes and Margo

against the Defendants, individually and jointly, for
compensatory and punitive damages and
attorney's fees, together with interest and costs of suit,
and any other such relief this Court
COUNT FOUR
Civil. Rights Violations: Cumberland County &

City of Vineland
io4. The preceding paragraphs z-io3 are incorporated by referen
herein.
WHEREFORE, the Plaintiffs, Gerald Sykes and Margot

Sykes, demand judgment
against the Defendants, individually and jointly, for compe
nsatory and punitive damages and
attorney's fees, together with interest and costs of suit, and
any other such re]ief this Court
COUNT FIVE
Due Process Violations

X05. The preceding paragraphs 1-~04 are incorporated by reference
as if set forth at length
herein.
xo6. Defendants' actions asset forth above violated Plaintiffs', Gerald Sykes
and Margot
Sykes, rights to substantive due process under the Fourteenth Amend
ment to the United States
Constitution by subjecting them to unlawful, arbitrary, capricious
and unjustified arrest.
107. Defendants' actions as set forth above violated Plaintiffs', Gerald
Sykes and Margot
Sykes, rights to procedural due process under the Fourteenth Amend
ment to the Unified States
Constitution by denying them necessary procedural protections in
connection with the
individually named Defendants, by the arrest, detainment, negligent
misinformation, and
unlawful imprisonment, including circumventing the State of New
Jersey, Office of the Attorney
General, Office of Information Technology, Office of Emergency Manag
ement, NJSP Emergency
Management Section and NJSP internal practices and procedures to provid
e a consistent,
27
reasoned, non-pretextual, and non-retaliatory criteri

a for their actions against Plaintiffs, Gerald
and Margot Sykes.
xo8. As a direct and proximate result of Defendants' action

s, Plaintiffs, Gerald and Margot
Sykes, were denied their due process rights and have
suffered damage in a forrr~ of constitutional
deprivation, emotional anguish and distress, damag
e to their reputation and other injuries.
109. As a further proximate result of Defendants' uncon
stitutional conduct, Plaintiffs, Gerald
and Margot Sykes, have been deprived of certain
valuable rights, including being free from
harassing eanduct and excessive force.
WHEREFORE, the Plaintiffs, Gerald Sykes and Margo

against the Defendants, individually and jointly, for comp
ensatory and punitive damages and
and ar~y other such relief this Court
COUNT SIX
State Constitufiional Violations

110. The preceding paragraphs x-xo9 are incorporated by
reference as if set forth at length
herein.
x11. The actions of the individual Defendants were taken in their

capacities as officials ar
employees of the Defendants, State of New Jersey, Office
of the Attorney General, State of New
Jersey Office of Information Technology, State of New Jersey
Office of Emergency Management,
New Jersey State Police, New Jersey State Police Emet~gency
Management Section, County of
Cumberland, Cumberland County 9-i-i Emergency Comm
unications Center, City of Vineland
and Vineland Police Department 9-~.-1 Communications Cente
r, and are therefore attributable to
them.
1x2. As a direct and proximate result of Defendants' actions, Plaint

iffs, Gerald and Margot
Sykes, were deprived of their rights under the New ,lersey
State Constitution as set forth above
and have suffered physical and emotional injuries and menta
l anguish.
28
WIIEREFORE, the Plaintiffs, Gerald Sykes and Margot

against the Defendants, individually and jointly, for campe
nsatozy and punitive damages and
attorney's fees, together with interest and costs of suit, and any
other such relief this Court
COUNT SEVEN
Ne~li~ence and/or Gross Negligence
i~.3. The preceding paragraphs x-r12 are incorporated by referen

herein.
114. The Defendants named above, including John/Jane Doe r-lo

directors, supervisors,
officers, servants, agents, assignees, delegates and/or employ
ees of the State of New Jersey;
John/Jane Doe 1z-2o directors, supervisors, officers, servants, agents
, assignees, delegates
and/ar employees of the Office of the Attorney General of the State
of New Jersey; John/Jane
Doe 21-3v directors, supervisors, officers, servants, agents, assigne
es, delegates and/or
employees of the State of New Jersey Office of Information Techno
logy; John/Jane Doe 3i-4o
directors, supervisors, officers, servants, agents, assignees, delegat
es and/or employees of the
State of New Jersey Office of Emergency Mana~em~nt; John/Jane
Doe 41-ioo NJSP Troopers;
John/Jane Doe 1oi-z2o commanders, majors, lieutenants, sergeants,
chiefs and/or supervisors
of the NJSP; John/Jane Doe 12~-14o directors, supervisors, officers,
servants, agents, assignees,
delegates and/or employees of the New Jersey State Police Emergency
Management Section;
John/Jane Doe 141-15o directors, supervisors, officers, servants, agents,
assignees, delegates
and/or employees of the County of Cumberland and/or the Cumbe
rland County 9-1-1
Emergency Communications Center; JohnJJane Doe lei-x6o directors,
supervisors, officers,
servants, agents, assignees, delegates and/or employees of the City of
Vineland and/oz the
Vineland Police Department 9-1-~ Communications Center; and ABC
z61-1~o public entity,
company, corporation and/or other entity yet to be identified, are
responsible by their
knowledge, action and/or inaction as if all allegations set forth herein
pertaining to all
Defendants, individually and/or jointly, were set forth here as to these
said Defendants. The acts
29
of these said Defendants, described herein and above

, were undertaken and/or enabled by
and/or during the course of/or within the scope of his/he
r employment, appointment and/or
agency, with any of the Defendants, including the State
of New Jersey; Office of the Attorney
General of the State of New Jersey; State of New Jersey
Office of Information Technology; State
of New Jersey Office of Emergency Management; NJSP New
; Jezsey State Police Err~er~ency
Management Section; County of Cumberland; Cumberland
County g-1-1 Emergency
Communications Center; City of Vineland; and Vineland
Police Department 9-1-1
Communications Center.
zip. At all times material hereto, said Defendants knew and/or

reasonably should have
known of the unreasonable danger to Plaintiffs, Gerald Sykes
and Margot Sykes, due to
Defendants (who are yet to be identified but upon belief and
information bear state police badge
numbers X896 and X939) and any and all other state police
troopers similarly situated, as well as
Nardelli's, Branin's, Guzman's, Woolsey's, Swain's and Donof
lio's deviations from accepted state
police standards and/or practices and deviations from accept
ed and wrifiten NJSP professional
~, standards, 9-~-1 emergency telecommunication system operating
proced ures and standards,
policies and procedures as set forth in N.J.S..A. ~2:i~(c) -i et seq. and
N.J.A.C. 1 :24-i.1 et seq.
and any and all other professional standards and practices which
are applicable to the incidents
as set forth above.
1i6. Said Defendants knew and/or reasonably should have known that
yet to be identified
state police troopers bearing badge numbers X896 and 7939, and other
state police troopers
similarly situated, and g-1--~ telecommunicators Nardelli, Branin, Guzm
an, Woolsey, Swain and
Donoflio, posed an unreasonable risk of abuse and harm to
the Plaintiffs, Gerald Sykes and
Margot Sylces, husband and wife.
1i~. Said Defendants owed the Plaintiffs a duty to protect the Plaintiffs
directly and/or
indirectly fz-om the Defendants above named, both prior to and/o subse
r quent to the
Defendants' actions.
~31~
1i8, Said Defendants' willful, wanton and/or grossly

negligent acts of commission and/or
omission, resulted directly and/or approximately
in the damages set forth herein.
~x9. But for said Defendants' knowledge of Defendants yefi
to be identified state troopers
Dearing state police badge numbers 7896 and 7939,
and those similarly situated, and g-1-~
telecommunicators Nardelli's, Branin's, Gunman's,
~oolsey's, Swain's and Donoflio's failure to
act in conformance with accepted state police practi
ces and procedures and 9-x-1
telecommunications practices and procedures, and/o
r their willful, wanton and/or grossly
negligent acts or commissions and/or omissions, Plainf
iiffs, Gerald Sykes and Margot Sykes,
would not have been harmed in the manners in which
they were harmed, are presently harmed
and will continue to be harmed.
120. As a direct result of said conduct, Plaintiffs, Gerald Sykes

and Margot Sykes, have
suffered the injuries and damages described herein above
,
WHEREFORE, the Plaintiffs, Gerald Sylces and Marg
ot Sykes, demand judgment
against the Defendants, individually and jointly, for comp
ensatory and punitive damages and
COUNT EIGHT
Intrusion upon Seclusion

121. The preceding paragraphs 1-12o are incorporated by refere
nce as if set forth at length
herein.
122. The Defendants, Guzman and NJSP troopers yet to be ident

ified but bearing state police
badge numbers X896 and ~939~ by their negligent actions, inacti
ons, and/o r gross negligence,
physically intruded on the Plaintiffs' solifiude and seclusion
within their own private home and
private bedroom.
i23. A.5 a result of the aforesaid Defendants' actions, the Plain

tiffs have been damaged.
WIiEREFO~, the Plaintiffs, Gerald Sykes and Margot Sykes
, demand judgment
against the Defendants, Guzman and NJSP troopers yet
to be identified but bearing state police
3Z
badge numbers 7896 and ~y39, individually and jointly

, for compensatory and punitive
damages and attorney's fees, together with intere
st and costs of suit, and any other such relief
this Court deems equitable and just.
COUNT NINE
Supervisor Liabilitx
i24. The preceding paragraphs 1-1z3 are incorporated by
herein.
i25. Defendants, State of New Jersey; Office of the Attorney

General of the State of New
Jersey; State of New Jersey Office of Information Techn
ology; State of New Jersey Office of
Emergency Management; NJSP; New Jersey State Police
Emergency Management Section;
County of Cumberland; Cumberland County 9-i-1 Emergency
Communications Center; City of
Vineland; and Vineland Police Department 9-1-x Comm
unications Center; by and through their
directors, supervisors, officers, servants, agents, assign
ees, delegates and/or employees, all had
a duty to properly supervise their employees and failed
to do so. The said Defendants had actual
and/or constructive knowledge of Defendants' Nardelli, Brani
n, Guzman, Woolsey, Swain,
Donoflio and NJSP troopers yet to be identified but some bearin
g state police badge numbers
~ 7896 and ~g39, proclivities and/or improper behavior towards
others, including but not limited
to the Plaintiffs, and it is therefore reasonably foreseeable that
in the ordinary course of their
duties, the directors, supervisors, officers, servants, agents, assign
ees, delegates and/or
employees might present a threat of injury to the public.
i26. Defendants, State of New Jersey; Office of the Attorney Gener

al of the State of New
Jersey; State of New Jersey Office of Information Technology;
State of Never Jersey Office of
Emergency Management; NJSI'; New Jersey State Police Emerg
ency Management Section;
Andrew B. Johns; Dave 41~'einstein; Craig Reiner; Jennifer
Lichtenstein; Edward Conrow; David
~ J. Petersen; Charles Nardelli; John/Jane Doe x-10 directors,
supervisors, officers, servants,
agents, assignees, delegates and/or employees of the State of Ne~.~
Jersey; John/Jane Doe 1i-2o
directors, supervisors, officers, servants, agents, assignees, delega
tes andf or employees of the
32
Office of the Attorney General of the State of New

Jersey; John/Jane Doe 2~-3o directors,
supervisors, officers, servants, agents, assignees,
delegates and/or employees of the State of New
Jersey Office of Information Technology; John/Jane
Doe 31-4o directors, supervisors, officers,
servants, agents, assignees, delegates and/or
employees of the State of New Jersey Office of
Emergency Management; John/Jane Doe Xoi-~
2o commanders, majors, lieutenants, serge ants,
chiefs and/or supervisors of the N~TSP; John/Jane
Doe 12~.-i4o directors, supervisors, officers,
servants, agents, assignees, delegates and/or
employees of the New Jersey State Police
Emergency Management Section; John/Jane Doe
141-15o directors, supervisors, ofCcers,
servants, agents, assignees, delegates and/or emplo
yees of the County of Cumberland and/or
Cumberland County 9-1-~ Emergency Communica
tions Center; John/Jane Doe x51-160
ees, delegates and/or employees of the
City of Vineland and/or the Vineland Police Depa
rtment 9-i-1 Communications Center; and
ABC 16~-1~o public entity, company, corporation and/o
r other entity; were, at all relevant times,
supervisory personnel in the State of New Jersey; and/o
r Office of the Attorney General of the
State of New Jersey; and/or State of New Jersey Office
of Inform ation Technolog3~; and/or State
of New Jersey Office of Emergency Management; and/o
r NJSP; and/or New Jersey State Police
Emergency Management Section; and/or the Coun
ty of Cumberland, and/or City of Vineland;
and/or the Vineland Police Depaztment g-i-~ Communica
tions Center; with oversight
responsibility for Defendants Branin; Guzman; Wool
sey; Swain; Donoflio; and NJSP troopers
yet to be identified but some bearing state police badge
numbers X896 and X939 and other
troopers similarly situated. They were responsible for
the traini ng, instruction, supervision and
discipline of the officers, employees, agents, servants
and/or volunteers who violated the
constitutional rights of Plaintiffs, Gerald Sykes and Marg
ot Sylces, in the matter described above.
The supervisory Defendants hereinabove named, as super
visory personnel in the legal entity set
forth above, owed a duty of care to the Plaintiffs, Gera
ld Sykes and Margot Sykes, to prevent the
conduct alleged, which foreseeability caused their injuri
es and violations of their civil rights.
33
i2~. The aforesaid supervisory Defendants had a duty

to exercise reasonable care, in
continual formation of the officers, employees,
agents, servants and/or volunteers, including the
screening, selection, training, supervision, reten
tion, assignment, transferring, appointment
and/or employing of Defendants Branin, Guzman,
Wool sey, Swain, Donoflio and NJSP troopers
yet to be identified but bearing state police badge
numbers ~8g6 and 7939, and other troopers
similarly situated, for the work assigned to them
and for the purposes of determining their
fitness for access to the public, including Plain
tiffs, and were negligent and/or grossly negligent
in that said Defendants failed to adopt and estab
lish reasonable and/or adequate policies,
guidelines or other means whereby they would learn
to recognize an officers, employees, agents,
servants and/or volunteers propensity for rogue or
deviant behavior or the behavior itself, failed
to adequately screen and/or investigate the indi~~idually
named said Defendants regarding their
candidacy for an officez, employee, agent, servant and/o
r volunteer. The Defendants further
failed fio adequately investigate the aforementioned indiv
idually named Defendants' prior
activities and/or behavior with regard to the public, and
failed to adequately monitor and/or
investigate the aforementioned individuals during their
training and conduct prior tU each
change in assignment and/or appointment and/or position
of said individual Defendants, as
officers, employees, agents, servants and/or volunteers.
i28. The Defendants had an ongoing duty to keep and maintain

the aforesaid individually
identified Defendants under continuous and/or reasonable
supervision that provided assurance
that the individually named Defendants were fit to perform
their employment and/or assign or
appointed responsibilities and did not present a risk to the
health, safety and welfare of those
individuals, including these Plaintiffs who would reasonably
be expected to come into contact
with the aforesaid individually named Defendants as
a result of their employment and/or duties
and responsibilities of their assignments and/or appointme
nts while an officer, employee, agent,
servant, and/or volunteer, and to retain them only as long
as they are fit and competent.
x.29. The failure of the Defendants to train, supervise and discip
line the aforesaid individually
named Defendani:s amounted to gross negligence, delibe
rate indifference, or reckless
34
misconduct and/or willful, wanton, malicious,

reckless and/or outrageous conduct in their
disregard for the rights and safety of the Plain
tiffs, which directly caused and vas the mo~rin~
force behind the depravations and injuries
suffered by the Plaintiffs, Gerald Sykes and Marg
ot
Sykes.
~.~o. Defendants, State of New ~Tersey; Office of the Attorn

ey General of the State of New
Jersey; State of New Jersey Office of Information Techn
ology; State of New Jersey Office of
Emergency Management; NJSP; New Jersey State
Police Emergency Management Section;
County of Cumberland; Cumberland County g-1-1
Emergency Communications Center; City of
Vineland; and Vineland Police Department 9-1-z
Communications Center; along with
John/Jane Doe ~-Zo directors, supervisors, officers,
servants, agents, assignees, delegates
and/or employees o~the State of New Jersey; John
/Jane Doe xx-2o directors, supervisors,
officers, servants, agents, assignees, delegates and/o
r employees of the Office of the Attorney
General of the State of New Jersey; John/Jane Doe
2~-3o directors, supervisors, aff'icers,
yees of the State of New Jersey Office of
Information Technology; John/Jane Doe 3i-4o direc
tors, supervisors, officers, servants, agents,
assignees, delegates and/or employees of the State
of New Jersey Office of Emer gency
Management; John/Jane Doe ~0~.-12o commanders, majo
rs, lieutenants, sergeants, chiefs
and/or supervisors of the NJSP; John/Jane Doe i21-14o direct
ors, supervisors, officers,
servants, agents, assignees, delegates and/or employees
of the New Jersey State Police
Emergency Management Section; John/Jane Dae 14x-1
5o directors, supervisors, officers,
servants, agents, assignees, delegates andf or employees of
the County of Cumberland and/ar
Cumberland County 9-1-i Emergency Communications Cente
r; John/Jane Doe 15z-z6o
directors, supervisors, officers, servants, agents, assignees,
delegates and/or employees of the
City of Vineland and/or the Vineland Police Departmen
t 9-1-1 Communications Center; and
ABC 16~-i~o public entity, company, corporation and/oi
other entity, as employers) of the
aforesaid individually named Defendants, Johns, Weinstein,
Reiner, Conrow, Lichtenstein,
Petersen, Nardelli, Branin, Guzman, Woolsey, Swain, Dono
flio, and John/Jane Doe 4i-xoo
35
NJSP troopers (yet to be identified but with some

bearing badge numbers, including but not
limited to '78 9~~ 7939 7479
7735 7622 7542, 7737 7$27 78i3~ 7912, X802, x$22, 7913, 775g>
7622 7343 5637 53b1~ 7913 589
7 7434) and the additional aforementioned yet to be identified
fictitious John/Jane Doe defendants, are responsible
fir their wrong-doing under the Doctrine
of Kespondeat Superior and the New Jersey Tort Claim
s Act, N.J.S.A. 59:2-2 et seq.
13i. As a direct result of the negligence and/or grossly neglig
ent conduct, the Plaintiffs,
Gerald Sykes and Margot Sykes, have suffered and will
continue to suffer the injuries and
damages described herein.
WHEREFORE, the Plaintiffs, Gerald Sykes and Marg

ot Sykes, demand judgment
against the Defendants, individually and jointly, for
compensatory and punitive damages and
COUNT TEN
Common Law Negligence Provision of Medical
Care
x.32. The preceding paragraphs 1-13~ are incorporated by refere
herein.
133. Defendants, Johns; Weinstein; Reiner; Conrow; Lichtenstein

; Petersen; Nardelli;
Branin; Guzman; Woolsey; Swain; Donoflio; John/Jane Doe
41-~0o NJSP troopers (yet to be
identified but with some bearing badge numbers, includ
ing but not limited to ~896~ 7939, 7479
7735> 762~~ 7542 7737, 7$2'7 78~3~ 7912, 78oz, 7322 7913,
775g~ 7622, 7343, 5637, 5361-, 7913
5897 7434) John/Jane Doe 1-lo directors, supervisors, officers, servants, agents, assignees,
delegates and/or employees of the State of New Jersey; John/
Jane Doe zl-2o directors,
supez~visors, officers, servants, agents, assignees, delegates and/o
r employees of the Office of the
Attorney Genera] of the State of New Jersey; John/Jane Doe
21-3o directors, supervisors,
officers, servants, agents, assignees, delegates and/or emplo
yees of the State of New Jersey
Office of Information Technology; John/Jane Doe 31-4o direct
ors, supervisors, officers,
servants, agents, assignees, delegates and/or employees
of the State of New Jersey Office of
36
Emergency Management; John/Jane Doe iol-12o comm

anders, majors, lieutenants, sergeants,
chiefs and/or supervisors of the NJSP; John/Jane
Doe ~2i.-14o directors, supervisors, officers,
yees of the New Jersey State Police
Emergency Management Section; John/Jane Dae
z41-i5o directors, supervisors, officers,
yees of the County of Cumberland and/or
Cumberland County 9-1-i Emergency Communications
Center; John/Jane Doe ~5i-16o
ees, delegates and/or employees of the
City of Vineland and/or the Vineland Police Departmen
t 9-1-i Communications Center; and
others similarly situated yet to be known to ~~ze Plaintiffs,
acting in their individual and official
capacity, and as NJSP troopers and/or g-i--~ fielecommunic
ators for the State of New Jersey
and/or the NJSP and/or the County of Cumberland and/o
r the City of Vineland, and within the
scope of their employment, negligently failed to provide prom
pt and adequate medical care to
the P}.aintiff, Gerald Sykes, after he was the victim of the illega
l, unreasonable and excessive use
of force which resulted in the severe, life-threatening injurie
s described above. Defendants, State
of New Jersey; Office of the Attorney General of the State of New
Jersey; State of New Jersey
Office of Information Technology; State of New Jersey Office
of Emergency Management; New
Jersey State Police; New Jersey State Police Emergency Manageme
nt Section; County of
Cumberland; Cumberland County 9-1-1 Emergency Communicat
ions Center; City of Vineland;
and Vineland Police Department 9-1-i Communications Center;
by and through their directors,
supervisors, officers, servants, agents, assignees, delegates and/o
r employees, and as employers
of the aforesaid identified individual Defendants, are responsible
for their wrong-doing under
the Doctrzne of Res~ondeat Superior and the New Jersey Tort Claim
s Act, N.J.S.A. 59:2-2 et seq.
z34. As a direct and proximate result of the Defendants' misconduct
and abuse of authority
detailed above, Plaintiffs, Gerald Sykes and Margot Sykes sustai
ned the damages herein before
alleged.
V1~3EREFORE, the Plaintiffs, Gerald Sylces and Margot Sykes, dema

nd judgment
against the Defendants, individually and jointly, for compensatory
and punitive damages and
37

COUNT ELEVEN
Negligent Infliction of Emotional Distress
i35. The preceding paragraphs 1-i34 are incorporated by refere

herein.
136. As described aforesaid, the actions of the Defendants

were done in a negligent and/or
grossly negligent manner.
137. As a direct and proximate result of the Defendants' negligence

and/or gross negligence,
the Plaintiffs, Gerald and Margot Sykes, suf-~ei-ed the injurie
s and damages described herein,
including but not limited to, mental and emotional distres
s.
WIiER.EF~R.E, the Plaintiffs, Gerald Sykes and Margot Sykes,
demand judgment
against the Defendants, indi~~idually and jointly, for compensator
y and punitive damages and
other such relief this Courfi
COUNT TWELVE
Intentional Infliction of Emotional Distress
x38. The preceding paragraphs z-137 are incorporated by reference as

if set forth at length
herein.
i39. As described aforesaid, the Defendants', their predecessors and/o

r successors, agents,
servants and/or employees, actions and/or inactions were extrem
e and outrageous, and they
were conducted in an intentional and jor reckless manner with
the knowledge that severe
emotional distress and/or bodily harm to the public, including
these Plaintiffs, was certain
and/or substantially certain to result.
140. As a result and proximate result of Defendants' tortious condu

ct, the Plaintiffs, Gerald
and Margot Sylces, suffered the injuries and damages described
herein, including mental and
emotional dist~ess.
~41~HEREFORE, the Plainfiiffs, Gerald Sylces and

Margot Sykes, demand judgment
against the Defendants, individually and jointly,
for compensatory and punitive damages and
attorney's fees, together with interest and costs
of suit, and any other such relief this Court
COUNT THIRTEEN
Request for Punitive Damages

141. The preceding paragraphs 1-i4o are incorporated by
herein.
142. Defendants, either individually, jointly, and/or severally,

are liable by their actions
and/or implied constructive inactions and actual inacti
ons with regard to their knowledge,
actual and/oar otherwise, and as such, are subjected to Plainf
iiffs' request of punitive damages.
143. Defendants' conduct as aforesaid was willful, wanton, malic
ious, reckless, and
outrageous and was grossly negligent in nature.
144. As a direct and indirect result of said conduct, including

actions and inactions, Plaintiffs,
Gerald Sykes and Margot Sykes, have suffered the injurie
s and damages described herein.
WHER.EF4RE, the Plaintiffs, Gerald Sykes and Margot
against the Defendants, individually and jointly, for compensat
ory and punitive damages and
other such relief this Court
PUFF & COCKERILL L.L.C.

,~ ~ _ a;i.
~, ~ /
Dated: ~}~.~'~-~ ,_j /, ~_,.
:~
,r~ /;/` '~-Richard S. Kaser, Esquirey
Attorneys) for Plaintiffs
39
DESIGNATION OF TRIAL COUNSE

L
Richard S. Kasen, Esquire is hereby designated
trial counsel of reco~,d.
Dated: f ;~,~; <.-, ~-

By; .:~~;" %'-<.:,.;~ ~ ;:r~
' ~'~ =~~Zxchard S. Kasen, Esquire
DED~IAND FOR JURY TRIAL
The Plaintiffs) hereby demands a trial by jury as

to all issues contained herein,
Dated: j~~~' ~f;~% ~~ ,.;;. .,.. %

By: :/' ~~~;y. r,-' /~,//< :ate'
i
~~-. ..
~'~ '?' ' ~' ~ ~.i.chard S. Kasen,, Esquire
l Attorneys) for Plaintiffs
CERTIFICATION PURSUANT TO RULE 4:
This is to certify that, to the best of my knowledge

, the matter in controversy is not the
subject of any other action pending in any court or of pend
a ing arbitrafiion proceeding, nor is any
other action or arbitration proceeding contemplated.
Further, at this time, there are no known
other parties who should be joined in this action.

--.
Dated: ~,~ i~:,,, ~ ~, B ~ ;;. .., ,...__....

/ .-~ ~'~'
;:Richard S. Kasen, Esquire
40
CERTIFICATION PUR,SUAN'r TO R.~:~8-7.~b)

Icertify that confidential personal identifiers have
been redacted from documents
submitted to the court, and will be redacted from all
documents submitted in the future in
accordance wiih Rule z:38-~(b).
Dated.: `.,~ J ~ y. ,,- , ~:- ~ .. ;:..

,R~i'hard S. Kaser, Esquire
NOTICE TO PRQDUCE DOCUMENTS

INSTRUCTIQNS .AND DEFINITIONS
Please take notice that the undersigned Attorney for the

Plaintiff(s), Gerald Sykes and
Margot Sykes, et al., pursuant to New Jersey Court
Rules 4: ~8-~., et seq., demands that the
Defendants) produce the following dUcuments for inspec
tion and copying at the Law Offices of
Puff & Cocicerill, L.L.C., 122 Delaware Street, P.Q. Box 684,
Woodbury, New Jersey 08096-0684,
according to the Rules of Court.
This request is intended to cover all documents in you and

your client's possession or
subject to you or his custody or control, whether or not they
are located in any of the answering
parties' offices or any other offices maintained by the answering
party or controlled by them. It is
also intended to cover all documents that you are only authorized
to retrieve, including but nat
limited to financial documents and/or medical documents.
As used in this request, the term " ... document ... "mea
ns without limitation the
following items whether printed or recozded or reproduced
by any other mechanical process or
written or produced by hand; agreements, communications,
state and federal governmental
hearings and reports, correspondence, telegrams, memo
randum, summaries or records of
telephone conversations, summaries or records of personal
conversations or interviews, diaries,
graphs, reports, notebooks, notecharts, plans, drawings, sketch
es, maps, summaries or other
records of meetings or conferences, summaries or reports
of investigations or negotiations,
opinions of reports or consultations, photographs, motion pictur
e film, brochures, pamphlets,
advertisements, circulars, press releases, drafts, letters, any margi
nal comments appearing on any
and all documents, and all other writings.
The word " ... parties ... ", " ... party ... " or " ... answering
parties ... "means the
person to whom these requests are directed and who is a party
to this litigation, including that
party's attorney, agents, employees, heirs, servants or anyone under
his control or direction who
is capable of retrieving documents which are dzscaverable.
:~I
1. Each and every writing as defined in the New

Jersey Rules of Evidence which pertain in any
way to that which is the subject of the prese
nt action, including but not limited to, answers to
interrogatories;
z. Each and every writing as defined in the New

Jersey Rules of Evidence which pertain in any
way to all claims and/or defenses filed by or made
on behalf of any Plaintiff s) f Defendants) that
which is the subject of the present action;
3. Each and every writing as defined in the New Jerse

y Rules of Evidence which pertain in any
way to that which is the subject matter of this comp
laint and the complaint filed by the Plaintiff;
4. The entire contents of ally investigation file and/o
r
in your possession which support any alleged claim files and any other documentary material
/defense or which in any way relates to the
allegations or defenses contained in the pleadings filed
in this action;
5. Any and all statements as defined in the New Jerse
y Rules of Evidence concerning this action
from any and all witnesses including any statem
ents from the parties herein or their agents,
servants and/or employees;
6. Any and all documents, written statements, record

ed statements, summaries of inteiti-iews
concerning the above-captioned litigation made by any
of the parties to this litigation or by any
witnesses to the events set forth in the Plaintiffs comp
laint or Defendant's answer or separate
defenses;
~. Any and all photographs and/or diagrams of the area

allegedly involved in this accident or
occurrence, the vehicles involved in the accident or -any other
diagram andJor photograph of any
event set forth in Plaintiff s complaint or any Defendant's
Answer or separate defenses;
8. Any and all accident and/or investigation reports conce
rning this accident or occurrence, no
matter by whom prepared, excluding only items protected
by privilege;
9. Any and all repoxts, correspondence, memoranda and
documents rendered or prepared by any
', expert witness employed by or consulted by the party to whom
Documents is directed or anyone acting on such parties' behal this Request fnr Production of
f concerning this matter;
lo. ,any and all documents referenced in your answers to interr
ogatories;
~ x. Copies of any and all documents produced in response to any
other parties' interrogatories and
request for production of documents, or produced by any other
party in response to your request
for production of documents or interrogatories;
i2. Any and all documents that the Defendant intends to introd
uce at the time of trial;
i3. Any and ail documents, written statements, recorded statem
ents, summaries of interviews
concerning the above -captioned litigation made by any of
the parties to this litigation or Uy any
witnesses to the events set forth is the Plaintiff's complaint or
any Defendant's answer or separate
defenses;
x4. Any and all reports or documents obtained from any gover
nmental agency, fire or police
department pertaining to the incident or' occurrence in quest
ion;
~5. In cases involving motor vehicle accidents, any and all cellul
ar phone bills for the month in
which the accident occurred;
42
16. The discoverable contents of your inves

tigation
4:18-x(a); R. 4:~0-2 and its subparfis, including file regarding this matter consistent with R.
R. 4:10 -2(c);
1~7. Any tangible objects which were in any
way involved in the matters which are the subje
this lawsuit; ct of
18. Any and all names and addresses of anyone

contacted with respect to the investigation of the
matters which are the subject matter of this laws
uit whether or not such individuals will be called
as witnesses at the time of trial;
z9. Any and all diaries, journals or Iog books whic

h reference the matters which are the subject of
this lawsuit;
20. Any and all photographs, diagrams, charts, maps

, sketches, drawings, etc., pertaining to the
any of the matters that are subject to the present
lawsuit;
21. .Any and all police, fire, ambulance
or other reports pertaining to any of the matters that
subject to the present lawsuit; are ~,
22. Copies of any and all written documentation

between any of the parties to this lawsuit
pertaining to any of the matters that are subject
to the present lawsuit including, but not limited
to invoices, purchase orders, memoranda, corre
spondence, notes, agreements, leases and
contracts (including all addenda and riders.);
23. Copies of any and all written documentation to

or from any party to this lawsuit to or from
any third party concerning the subject matter of this
lawsuit including but not limited to invoices,
purchase orders, memoranda, correspondence,
notes, agreements, leases and contracts
(including all addenda and riders.);
24. Certified copies of any and all insurance policies

(including all endorsements) and declaration
j sheets covering any party to this matter which were
in effect for the matters which are the subject
of the present lawsuit.
25. Any and all incident reports and statements rega

rding this matter.
A response to this request must be sez-ved within thzrty
this request upon you. (30) days from the date of service of
NOTICE FURSUANT TO RULES x:a-1(ALand

4:~~q.
PLEASE TAKE NOTICE that the undersigned attor
ney dogs hereby demand,
pursuant to the abr~ve-cited Rules of Court, that each
party herein serving pleadings and
interrogatories and receiving answers thereto, serve
copies of all such pleadings and answered
interrogatories, and all documents, papers and other
material referred to therein, received from
43
ny party, upon the undersigned attorney and

TAKE NO"I'ICE that this is a CONTINUING
)EMANU.
PUFF & C~CKERILL L.L.C.

..- ~,;
~ / ;.,:~
~ ,% : :' 'a ~ chard S. Laser, Esquire

i
~~~ ~~ Atfiorney(s) for Plaintiffs
44
Appendix XTI-B1
CiVIL CASE INFORMATION ST .-

ATEMENT PAYMENT TYPE:
~~p~~aRaogO~Oo
~C ~ V~
CK ~~ ~A
CHG/CK N0.
o ~W a~~
C7 O ~~ ~
c~ Use for initial Law Division
o~o ~~oo Civil Part pleadings (nof motions) und AMOUNT:
`~0000Q o~00000 er Rule 4:5-1
Pleading will be rejected for filing,
under Rule 1;5-6(c),
if information above the black bar OVERPAYMENT:
is not completed
or attorney's signature is not affix
ed BATCH NUMBER:
ATTORNEY /PRO SE NAME
TELEPHONE NUMBER COUNTY OF VENUE
Richard S. Kaser, Esq.
(856) 845-0011 Cumberland
FIRM NAME (if applicable)
Puff & Cockerill, LLC DOCKET NUMBER (when available)
OFFICE ADDRESS
122 Delaware St. DOCUMENT TYPE
PO Box 684 Complaint
Woodbury, NJ 08096
JURY DEMAND ~ YES No
NAME OF PARTY (e.g., Jahn Doe, Plain
tiff CAPTION
Gerald Sykes and Margot Sykes,
h/w, Plaintiffs Gerald Sykes and Margot Sykes, h/w
v.
State of New Jersey, et al.
CASE TYPE NUMBER
HURRICANE SANDY
(See reverse side for listing) RELATED? IS THIS A PROFESSIONAL MALPRA
CTICE CASE?
005 YES ~ NO YES NO
IF YOU HAVE CHECKED "YES," SEE
N.J. S.A. 2A:53 A -27 AND APPLICAB
REGARDING YOUR OBLIGA710N TO LE CASE LAW
RELATED CASES PENDING? FILE AN AFFIDAVIT OF MERIT.
IF YES, LIST DOCKET NUMBERS
D vas ~o
D O YOU AN~i'ICIPATE ADDING ANY
PARTIES NAME OF DEFENDANT'S PRIMARY
(arising out of same transaction or INSURANCE COMPANY (if known)
occurrence)?
YES ~ NO NONE
~ UNKNOWN
CASE CHARACTERISTICS FOR PUR

POSES OF DETERMINING IF CASE
DO PARTIES HAVE A CURRENT, IS APPROPRIATE FOR MEDIATIO
N
PASTOR IF YES, IS THAT RELATIONSHIP:
RECURRENT RELATIONSHIP?
EMPLOYER/EMPLOYEE
YES FRIEND/NEIGHBOR
~ NO FAMILIAL OTHER (explain)
BU5INESS
DOES THE STATUTE GOVERNING
THIS CASE PROVIDE FOR PAYMENT
OF FEES BY THE LOSING PARTY?
USE l"HIS SPACE TO ALERT THE YES No
COURT TO ANY SPECIAL CASE CHA
ACCELERATED DISPOSITION RACTERISTICS THAT MAY WARRAN
T INDIVIDUAL MANAGEMENT OR
Complaint involves the shooting of
an elderly person by a New Jersey
house by 9-1-1. Many state and coun State Police officer who was sent to
ty employees named Defendants. the wrong
DO YOU OR YOUR CLIENT NEED

ANY OISABILI7Y ACCOMMODATfON
S? IF YES, PLEASE IDENTIFY THE
~,,,
~ YES ~ No REQUESTED ACCOMMODATION
WILL AN INTERPRETER BE
NEEDED?
YEs IF YES, FOR WHAT LANGUAGE
~ No ?
certify that confidential persona

l identifiers have been redacted
redacted from all document ~ from documents now submitted
ubmitted in the future in acco to the court, and wi11 be
rdance with Rule 1:38-7(b).
f ~~ ~~ ~~
ATTORNEY SIGNATURE
~~ ~
~
w~ ~'~/~
,.~, ~
r
~~ '~ J ~~;
, /;~ i
i..~
~
Effective 06!05/2017, CN 10517
page 1 of 2
CUMBERLAND COUNTY SUP~RIOk COURT

CIVIL CASE MANAGEI`~ENT
6 0 W BROAD ST
BRIDGETON NJ 08302
TRACK ASSIGNMENT NOTICE
COURT TELEPHONE N0. (856) 453-4330
COURT HOURS 8:30 AM - 4:30 PM
DATE: AUGUST 31, 2017

RE: SYKES ETAL VS STATE OF NEW JERSEY ETAL
DOCKET; CUM L -000626 17
THE ABO~~E CASE HAS BEEN ASSIGNED T0: TRACK 3.
DISCOVERY TS 450 DAYS I~ND RUNS FROM THE FIRST ANSWER OR 90 DAYS
FROM SERVICE ON THE FIRST DEFENDIaNT, WHICHEVER COMES FIRST.
THE PRETRIAL JUDGE ASSIGNED IS: HON JAMES R. SWIFT
IF YOU HAVE ANY QUESTIONS, CONTACT TEAM 101

AT: (856} 453-4393.
IF YOU BELIEVE THAT THE TRACK IS INAPPROPRIATE YOU MUST FILE A

CERTIFICA'T'ION OF GOOD CAUSE WITHIN 30 DAYS OF THE FILING OF YOUR PLEADING.
PLAINTIFF MUST SERVE COPIES OF THIS FORM ON ALL OTHER PARTIES TN ACCORDANCE
WITH R.4:5A-2.
ATTENTION:
ATT: RICHARD S. KA5ER
PUFF & COCKERILL LLC
122 DELAWARE ST
PO BOX 684
WOODBURY NJ 08096-7684
JUHGRIO

Upper Deerfield Police Shooting

Загружено:

Сведения о документе

Оригинальное название

Авторское право

Доступные форматы

Поделиться этим документом

Поделиться или встроить документ

Параметры публикации

Этот документ был вам полезен?

Это неприемлемый материал?

Авторское право:

Доступные форматы

Upper Deerfield Police Shooting

Загружено:

Авторское право:

Доступные форматы

Case 1:17-cv-07272-NLH-AMD Document 1-2 Filed 09/20/17 Page 1 of 50 PageID: 7

PUFF & COCKERILL, L.L.C.

MANAGEMENT (its divisions, departments,

SERVANTS, AGENTS, ASSIGNEES,

Dated: September 12, 201 ,/s/ M ~ ICI. S v~tiit~v

Names of Defendant to Be Served: ANDREW B. JOHNS

Address of Defendant to Be Served: State of New Jersey Office of the Attorney

PUFF & CUCKERILL, L.L.C.

MANAGEMENT (its divisions, departments,

SERVAN'T'S, AGENTS, ASSIGNEES,

The Plaintiff(s), GERALD SYKES and MARGOT

SERGEANTS, CHIEFS AND/OR SUPERVISORS of the New

3. At or about 11:39 p.m., several yet to be identified state police troope

z-i Emergency Communications Center and the Vineland Police

4. The currently known employees) of the Cumberland County g-z-1

5. The currently Icnown employees) of the Vineland Poliee Department

for three to four hours being interrogated without the benefit

1~. Mr. Sykes was flown by helicopter to Cooper Hospital where

was dressed only in her nightgown, as she was sleeping prior to

Communications Centers throughout the state of New Jersey and the

hiring/employment/supervision of all personnel of the New Jersey State Police.

25. Defendant, STATE OF NEW JERSEY OFFICE OF INFORMATION TECHNOLOGY

Communications Centers throughout the state of New Jersey.

z6. Defendant, STATE OF NEW JERSEY OFFICE OF EMERGENCY MANAGEMENT

divisions, departments, bureaus, sections, units, offices, agencies), is a government agency or

Communications Centers throughout the state of New Jersey.

the Plaintiffs hea-ein.

28. Defendant, NEW JERSEY STATE POLICE EMERGEI~TCY MANAGEMENT SECTION

divisions, departments, bureaus, sections, units, offices, agencies), is a government agency or

the Communications Bureau which processes the New

29. Defendant, COUNTY OF CUMBERLAND, is a govern

30. Defendant, CUMBERLAND COUNTY ~-i-x EMERGENCY

3i. Defendant, CITY OF VTNELAND, is a government agency or

32. Defendant, VINELAND POLICE DEPARTMENT g-i-~. COMML7NIC

33 Defendant, ANDRE4~r B. JOHNS, on July 2g, 2ox6, and dates prior

34 Defendant, DAVID WEINSTEIN, on July 2g, 2oz6, and dates prior

Information Technology, as Director, Office of Emergency Telecom

and in her official capacity as an employee of the State of New

41. Defendant, ANDREA DONOFLIO, on July 29, 2oi6, and dates

III. 1~GENCY ALLEGATIONS

employees, servants, pai-~ners, joint ventures, and representatives of each other,

principals, employees, servants, partners, joint ventures, and represen

Public Safety Telecommunicator, Newell Branin (hereinafter referred to as BRANIN

Fairfield Township section of Cumberland County.

transfer his call to the state police.

himself from said call.

54 Contrary to written policy, neither Branin nor his superv

55 The call that was initially and mistakenly transferred by Branin

56. Guzman advised, based on information and belief, Sgt. David

to them from Guzman. The state police troopers did not

66. The police troopers radioed to their headquarters at z~.:45:0

misconduct of the state police 9-x-1 telecommunicatorfoilm

state police while in her understandaUly extreme emotional distress

New Jersev Civil Rights Act

WHEREFORE, the Plaintiffs, Gez ald Sykes and Margo

86. The preceding paragraphs 1-85 are incorporated by referen

8~. All Defendants named herein above, acting under color of

8g. As a direct and proximate result of the Defendants misconduct

WHEREFORE, the Plaintiffs, Gerald Sykes and Margot Sylces, deman

Pattern and Practice

93 There have been numerous complaints of civil rights violations, includ

94 Defendants, collectively and individually, while acting under the

and its state police and g-1-i emergency personnel, which