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MID-L-006271-18 10/16/2018 3:53:42 PM Pg 1 of 18 Trans ID: LCV20181805180

GENOVA BURNS LLC


Angelo J. Genova, Esq. (005501979)
494 Broad Street
Newark, New Jersey 07102
(973) 533-0777
Attorneys for Plaintiff,
Daniel J. Reiman

DANIEL J. REIMAN, SUPERIOR COURT OF NEW JERSEY


LAW DIVISION: MIDDLESEX COUNTY
Plaintiff, Docket No: MID-L-
v.

MOHAMMED RADWAN CIVIL ACTION

Defendant. VERIFIED COMPLAINT

Plaintiff Daniel J. Reiman, by and through his attorneys, Genova Burns LLC, hereby files

this Verified Complaint, alleging as follows:

PARTIES

1. Plaintiff Daniel J. Reiman (“Plaintiff”) is the Mayor of Carteret, New Jersey and

the Democratic candidate for Mayor of Carteret, New Jersey in the 2018 General Election.

2. Defendant Mohammed Radwan (“Defendant” or “Radwan”) is a resident of

Carteret, New Jersey.

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VENUE AND JURISDICTION

3. This action is initiated in the Superior Court of New Jersey, Middlesex County, as

the facts and circumstances giving rise to these claims occurred within the boundaries of this

vicinage. Accordingly, pursuant to R. 4:3-2, venue is properly laid in the County of Middlesex.

FACTUAL BACKGROUND

4. On or about October 12, 2018, Defendant published and distributed physical copies

of a 5-page letter stating, in pertinent part, “Daniel Reiman is a sexual predator who preys upon

under-aged boys. I know, because I have witnessed and experienced it myself.” (the “False

Letter”).

5. The False Letter states that Plaintiff engaged in the following acts: 1) “Send

inappropriate texts, videos, etc.”; 2) “Ask for sexual favors and promise all sorts of jobs when he

got elected Mayor”; 3) “constantly try to grab my and other teenagers’ private parts or expose his

genitalia when others weren’t around”; and 4) “Demand sexual favors when I was in his car.”

6. On or about October 14, 2018, Defendant published a post from his personal

Facebook account “Moe Radwan” in which he alleges that Plaintiff sexually assaulted Pedro

Morquillas, Jr., a resident of Carteret, New Jersey (“Morquillas”), and states, “I’m doing just fine

and have no interest in working in a town that is run by a Sex Predator.” (the “Post”).

7. The statements in the False Letter and the Post – that Plaintiff sexually assaulted

minors, sexually assaulted Morquillas, and is a sexual predator – are false and defamatory per se

as they imply that Plaintiff engaged in criminal behavior.

8. Plaintiff has never committed any criminal activities as described by Defendant.

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9. Indeed, in a signed statement from Morquillas, he states that Plaintiff never sexually

assaulted him. Attached hereto at Exhibit 1 is a true and correct copy of the signed statement from

Morquillas.

10. The False Letter and Post were published less than a month before the 2018 General

Election for the sole purpose of smearing Plaintiff’s reputation in the eyes of Carteret residents

and voters.

11. Further, in a signed statement from Defendant’s wife, Amanda Radwan, she states

that Defendant wants to destroy Plaintiff and remove him from public office. Attached hereto at

Exhibit 2 is a true and correct copy of the signed statement from Amanda Radwan.

FIRST COUNT

(DEFAMATION PER SE)

12. Plaintiff repeats and reallege the allegations set forth in the foregoing paragraphs of

this Complaint as if set forth more fully herein.

13. The False Letter and Post published by Defendant are false and defamatory per se as

they imply that Plaintiff engaged in criminal activities.

14. The False Letter and Post were distributed to a third party or parties without privilege.

15. The False Letter and Post were made with reckless disregard of the truth, or with

knowledge of the falsity of the statements.

WHEREFORE, Plaintiff demands judgment against Radwan on Count One as follows:

(a) For a permanent injunction enjoining and restraining Defendant and all persons or

organizations who are associated therewith from publishing defamatory statements

regarding Plaintiff;

(b) For compensatory and punitive damages in an amount to be decided at trial;

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(c) For fees and costs, including reasonable attorneys’ fees;

(d) For such other and further relief as the Court may deem just and equitable.

GENOVA BURNS LLC


Attorneys for Plaintiff,
Daniel J. Reiman

s/Angelo J. Genova
ANGELO J. GENOVA
Dated: October 16, 2018

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DESIGNATION OF TRIAL COUNSEL

Pursuant to R. 4:5-1(c), Angelo J. Genova, Esq. is hereby designated trial counsel on behalf

of Plaintiff.

GENOVA BURNS LLC


Attorneys for Plaintiff,
Daniel J. Reiman

s/Angelo J. Genova
ANGELO J. GENOVA
Dated: October 16, 2018

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CERTIFICATION

I hereby certify pursuant to R. 4:5-1(b) that the matter in controversy is not the subject of

any other action pending in any court or of a pending arbitration proceeding, nor is any other action

contemplated. I further certify that there are no other parties who should be joined in the action

pursuant to R. 4:28, or who is subject to joinder pursuant to R. 4:29-1(b).

GENOVA BURNS LLC


Attorneys for Plaintiff,
Daniel J. Reiman

s/Angelo J. Genova
ANGELO J. GENOVA
Dated: October 16, 2018

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EXHIBIT 1
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EXHIBIT 2
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MID-L-006251-18 10/16/2018 2:35:07 PM Pg 1 of 6 Trans ID: LCV20181804251
MID-L-006251-18 10/16/2018 2:35:07 PM Pg 2 of 6 Trans ID: LCV20181804251
MID-L-006251-18 10/16/2018 2:35:07 PM Pg 3 of 6 Trans ID: LCV20181804251
MID-L-006251-18 10/16/2018 2:35:07 PM Pg 4 of 6 Trans ID: LCV20181804251
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MID-L-006251-18 10/16/2018 2:35:07 PM Pg 6 of 6 Trans ID: LCV20181804251
MID-L-006252-18 10/16/2018 2:37:56 PM Pg 1 of 7 Trans ID: LCV20181804537
MID-L-006252-18 10/16/2018 2:37:56 PM Pg 2 of 7 Trans ID: LCV20181804537
MID-L-006252-18 10/16/2018 2:37:56 PM Pg 3 of 7 Trans ID: LCV20181804537
MID-L-006252-18 10/16/2018 2:37:56 PM Pg 4 of 7 Trans ID: LCV20181804537
MID-L-006252-18 10/16/2018 2:37:56 PM Pg 5 of 7 Trans ID: LCV20181804537
MID-L-006252-18 10/16/2018 2:37:56 PM Pg 6 of 7 Trans ID: LCV20181804537
MID-L-006252-18 10/16/2018 2:37:56 PM Pg 7 of 7 Trans ID: LCV20181804537
MID-L-006254-18 10/16/2018 2:46:44 PM Pg 1 of 5 Trans ID: LCV20181804603
MID-L-006254-18 10/16/2018 2:46:44 PM Pg 2 of 5 Trans ID: LCV20181804603
MID-L-006254-18 10/16/2018 2:46:44 PM Pg 3 of 5 Trans ID: LCV20181804603
MID-L-006254-18 10/16/2018 2:46:44 PM Pg 4 of 5 Trans ID: LCV20181804603
MID-L-006254-18 10/16/2018 2:46:44 PM Pg 5 of 5 Trans ID: LCV20181804603

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