turner v nj dept of children and families
TRANSCRIPT
7/23/2019 Turner v NJ Dept of Children and Families
http://slidepdf.com/reader/full/turner-v-nj-dept-of-children-and-families 1/14
•
)
MAZIE SLATER KATZ FREEMAN,
LLC
Beth G. Baldinger (Attorney ID# 032681985)
103 Eisenhower Parkway
· ~ · · · · · · ~ · · · · · · ~ ~
1\ ¥1'
n
ll 2a1 1
·I
~ u . . \m :
· ·····
.:.:. · ··.
:.
oseland, New Jersey 07068
(973) 228-9898
Attorneys for Plaintiffs
KAMELIA TURNER, as Administrator
Ad
Prosequendum of the Estate ofN
A P T , deceased
Plaintiff,
vs.
STATE
OF NEW
JERSEY;
DEPARTMENT OF CHILDREN AND
FAivliLIES; DIVISION OF CHILD
PROTECTION
AND PERMANENCY
(FORMERLY KNOWN AS THE DIVISION
OF
YOUTH AND FAMILY SERVICES);
JOHN DOES 1-30,
Defendants.
··
·
.... ;· ·. :./:. -.···;: ;
SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: ESSEX COUNTY
DOCKET NO.: ESX-L- 'J... }.}f-f.5
CIVIL ACTION
COMPLAINT
AND
JURY DEMAND
Plaintiff, Karnelia Turner,
as
Adminlstrator
Ad
Prosequendum
of
the Estate
ofNevaeh
Anaisa Paris Turner, residing in Parlin, New Jersey, by way of Complaint against the
. .
de.fendants alleges and says:·
PARTIES
1. At all relevant timeS herein, plaintiff Kamelia Turner ( Turner ).was the mother·
ofNe .Anaisa P T ( N ). N was
bom
on November
14
2006 and died
on November 23, 2009. Turner currently resides at 3402 Wells Drive, Parlin, Middlesex
County, New Jersey.
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2. t all relevant times herein, defendants State of New Jersey, Department of
Children and Families, Division
of
Child Protection and Permanency (formerly known
as
the
Division
of
Youth and Family Services)(hereinafter collectively referred to as DYFS ) with local
offices in Newark, New Jersey and Union, New Jersey were responsible for the oversight and
protection
oftbe
health, safety and welfare
of
children.
3. At all relevant times herein, defendants John Does (1-30) (fictitious designation for
persons whose identities are currently unirnown) were employees or agents
ofDYFS
and/or ABC
Entities (1-30)(:fictitious designation for entities, private or public, whose identities are currently
unirnown) acting in the comse and scope of their employment, engagement and/or as agents for
defendants in this action and are otherwise liable and responsible for plaintiff's damages.
F CTS
4. From approximately May
of
2007 through June
of
2009, when N was 6
mon1hs old through 2
z
years old, she was a dependent under the care, custody and supervision
of
Union Cotmty Children and Youth Services in Union County, Pennsylvania ('UCCYS ). During
this period
of
time, N was placed
by
UCCYS in a stable, loving foster home
n
Pennsylvania
and her foster family was seeking to adopt her.
5
· n or around 2008 and early 2009, DYFS and John Does (1-10) conducted
paternity
~ s t i n g
and con:fi1med that Tamir Little was N 's biological father and sought
to
have him provide support for N
6.
. In or ~ o u n 2008 and early20.09, DYFS and John Does (1-30) took action to have
custody ofN transferred to Tamir Little. Their effmts resulted in an Order which te1minated
UCCY' s custody ofN and the transfer
of
custody ofN to Tarnir Little.
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7. On or about June 30, 2009, DYFS and John Does (1-30) placed N in the
home of Tamir Little ( Little ) which he shared with his paramour, Samirah Lightford
( Lightford ) and their child
(Baby Doe).
The
home
was located at
92
Campfield Street,
I r v i n ~ o n
Essex County, New
Jersey.
8. Following the June 30, 2009 placement ofN with Little and Lightford, upon
infmmation and belief, DYFS
and
John
Does (1-30)
remained involved with Little, Lightford, and
N , including but not limited to providing them with services and supervision.
9.
Following DYFS's·June
30,
2009 placement ofN with Little and Lightford,
N
evaelr was
seen on multiple occasions
at
the emergency room of Newark Beth Israel Medical
Center (''NBIMC ) in Newark, New Jersey for numerous injuries which
were
highly indicative of
abuse and neglect by non-accidental trauma, including but not limited to the following:
(a) On July 24, 2009 N was seen
and
treated for a head laceration
requh·ing
sutures.
(b)
On September 20, 2009 N was seen and treated for a bruise to her left
cheek and a broken front tooth which was broken in tbree places.
(c) On October
3,
2009 N was seen
and
treated for second degree burns
to
her hand.
(d) October 9, 2009 N was seen and evaluated for a hump on her back.
10.
On
or about October 5, 2009, N was seen by Kafilat
Adewmmli,
M.D: ( Dr.
Adewunmi ) for treatment o the
b\lffiS
to her hand and
r ~ f e r r l
to a burn specialist at which time
the following.condltious were
obsetYed.and
the following events occurred:
(a)
(b)
Dr. Adewunrui observed multiple scars and suspicious marks
all
over
N 's
body,
including
both
of her legs imd arms, as well as her
trun
a k, which l)e
suspected were
due to physical
abuse.
.
Dr. AdeWtmmi noted that N 's
demeanor
was guarded and
afraid.
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(c) Dr. Adewunmi noted that the parents - Little and/or Lightford - had no
explanation for the multiple
scars
and suspicious marks all over N s
body.
(d) Dr. Adewunmi noted that the parents - Little and/or Lightford - advised
that N had
been
recently placed with them
by DYFS
as she
had
former en in foster care in Pennsylvania and that she carne to them
with the scars and
marks.
(e) Dr. Adewnnmi followed-up with N s former social worker in
Pennsylvania to obtain the histoty
and
documentation
o
N s
conditions prior
to
being placed with Little. Hewever, a signed consent .
form from a parent
was
required
before
information could
be
released.
(f)
Dr.
Adewunmi requested that
Litt)e
sign the consent form. Little agreed
but only after he first contacted his lawyer. Little did not sign
the
consent
form.
11.
On
or about October 12, 2009 Dr. Adewumni made a repott
to DYFS o
suspected
child abuse and neglect ofN .
12. From June
30, 2009
to November 21,
2009, DYFS and
John Does (1-30) were
mandated to provide appropriate services and supervision q N ,in this placement, and were
mandated to properly
and
promptly investigate
the
report o child abuse and neglect o N
and to innnediately take all actions necessaty to ensure her safety.
13. On November 21,
2009
N was mshed by ambulance to NB]JY.[C where she
was
diagnosed with
an
acute traU Jlatic brain injmy with bilateral
acute
subdural hematomas
and
massive c e ~ e b r l swdling. She was also found
to
have mu\tiple abras ons on
both
shoulders
and
old loop marks on both thighs. These injuries, together.with those N previously presented
with
at NB]JY.[C on
prior 9ccasions,
were
consistent
with
a child
who
had been subjected
to
repeated acts o child b u s ~ and neglect.
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14.
On
November 21,
2009,
N underwent emergency cranial surgety
and was
placed on life snpport. On November 23, 2009, N was removed from life support and
passed
away.
15.
On or about February 2, 2010, Turner duly served a Notice of Claim in accordance
with N.J.S.A. 59:8-1 et. Six months have now lapsed
and
the claim remains unsatisfied.
16. On March
12,
2013, Tamir Little
pled
guilty
to
manslaughter charges
for
the death
ofN and on April 23, 2013 Tamir Little was sentenced.
17.
This wrongful death and surviv9rship action is timely and properly filed in
accordance with N.J.S.A. 2A:31-3.
FIRST OUNT
18.
Plaintiff repeats all the allegations pled in paragraphs 1 through 17' ' as though
fully set forth herein at length.
19.
On or
about October 12, 2009, DYFS and John Does (1-30) received the report o
child
abuse and
neglect ofN , and Dr. Adewunmi's report that she had multiple scars
and
marks all over her body that were suspicious for child abuse. DYFS leamed at that time
th t
N
had
second degree bums to her hand for
which
she had been seen
at NB.JN.fC
emergency
room; that slie presented as guarded and afi·aid; and that her parents -- Little
and
Lightford --had
no explanation for the scars and suspicious marks. At the time, N had 'only been in her
parents'
care
for approximately four months.
20.·
During the J;ime period o Jlme
30,
2009 through November 21, 2009, DYFS and
John
Does (1-30)
were under a mandatory duty to properly
provide
services
and
supervision o
Ne in this placement, and/or
to
follow the State laws, regulations, policies and procedures
which govemDYFS investigations of reports o child abuse and/or neglect, and were obligated to
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ensure the child, N , was safe and protected. These duties included, but are not limited to, the
following:
a) Immediately refer N and the case to the Regional Diagnostic and
Treatment Center at NBIMC for a child abuse exam; evaluation,
asseisment, medical record review, and other services;
(b) Obtain all
ofN s
medical records since she was placed on Jlme
30;
2009, including all records from NBIMC;
(c) Interview all physicians who exaruined and/or treated N since she
was placed on Jtme 30, 2009;
d) Conduct an initial and on-going safety and risk assessments;
e)
Develop, implement and monitor ·a ·safety plan ·that addressed the risks
·posed;
f) IdentifY the ' red flag' signs of abuse aqd/or neglect;
.. g) Recognize the 'high risk' factors present in this case and handle this
as
a
'high risk' case which included conferencing the case with the casework
supervisor and the Deputy Attomey Ge11eral;
(h) Interview the parents, separately, as
to
thei explatJ.ationfor all ofN 's
injuries and conditions and all other pertinent matters;
j) Conduct a home inspection and periodic visits;
k)
Conduct backgrolilld
checks,
including criminal record and Promis/Gavel
checks on both Little and Lightford;
1) .
( )'
Provide all services required by law, DYFS policies and procedures, as
well
as
any cmut's orders that _may have been in place goveining the
supervision ofN and the provision of services in tlus placement; and
Otherwise act to protect and ensme the health, safety and welfare of
N .
21.
During the time period of June
30, 2009
through November
21, 2009,
DYFS and
John Does (1-30) knew or should have known that their failure to: propedy provlde services and
supervision ofN 's placement; properly investigate this report
of
child abuse and neglect; and
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failure to act to protect and ensure the safety ofN from foreseeable risks of harm, iucludiug
irruninentrisks
ofhann
placed her iJJ.jeopardy for fmiher acts ofhann.
22.
Dmiug the time period of June
30, 2009 tfu:qugh
November
21 . 2009,
DYFS and
JohnDoes I
-30)
acted in a negligent, careless, reckless and/or palpably umeasonable manner iu
that they failed to properly provide services and supervision ofN 's placement, and failed to
properly follow and implement the mandatory procedures iu iuvesiigating the repoit ofchild abuse
and neglect as required by State
Jaws
and regulations: as well as DYFS's policies and procedures,
and/or court orders. Upon iufonnation and belief, the wrongful actions and/or omissions iuclude
but m·e not limited to the followiug:
(a) Failure
to
periodically and/or promptly visit N , conduct a visual
· iuspection of her body for signs of scars, suspicious marks, and/or other
injuries
or
conditions, and failme to properly document and photograph
them;
(b) Failure to immediately refer N and the case to the Regional
Diagnostic and Treatment Center at NBIMC for a child abuse exam by a
pediatric child abuse expert; and other evaluations, assessments, medical
record reviews, and services; ·
(b)
(c).
Failure to obtain all of N ' s medical records since she was placed
on
June 30, 2009, iucluding all records from NBIMC; and failure to verify
whether or not she received all follow-up medical and dental. care as
prescribedby physicians who saw ht<r;
Failure to iuterview physicians who examined and/or treated N
siuce she was placed on June
30, 2009,
iucluding physicians at NBIMC
and Dr. Adewumni;. ·
(d) Failure to have Dr. Adewuruni document the results of his exam ofN
and his fir diugs on a Child Abuse Exam Repmt or provide other
documentation as to his observations ofN
at
his exam on 09tober 5
2009;
(d) Failure to conduct initial and on-going safety and risk f\SSessments;
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(e) Fail
me
to develop, implement and monitor a safety plan that properly
addressed the risks posed
to
N ;
(f)
Failme to recognize and identify N 's multiple visits to NBIMC and
the injmies she presented with were 'red flag' signs
of
non-accidental
tramnatic nuuries indicative ofchild abuse and/or neglect;
(g) Faihue to recognize the 'high risk' factors present n N ' case and
t
hanc Je
this as a 'high risk' case which included conferencing the case with
the casework supervisor and the Deputy Attomey'General;
(h) Failme to interview the parents, separately, as to their explanation for
ll
of
N ' s injmies, scars, suspicious marks and other conditions and ll
other pertinent matters; ·
(i) Failme to conduct a home inspection and periodic visits to the home;
0) Failme to conduct background checks, including but not limited to criminal
record and Promis/Gavel checks on both Little and Lightford;
(k) Failure to confur with UCCY and N 's foster family as to any histoty,
documentation or treatroent of any injm1es, scars or suspicious marks on
N at
ap.y
time before June 30, 2009;
1)
Failme to review the results
of
DYFS's pre-placement physical exam for
any evidence of any scars or suspicious marks prior to her placement on
June 30, 2009;
(m)
Fai iJJg
to recognize that N did not have any injmies, scars or
suspicious marks on her prior to Jurie 30, 2009;
(n) Failing to recognize that N was at risk for fmiher abuse and neglect,
and in inrminent risk ofharm; and in failing to act to protect and ensu
health, safety and welfare, including but
not
limited to removing N
ii'otn 1ittle and Lightford' s custpdy or home pending completion of the
investigation. · ·
(0)
Otherwise failing to provide all
serVJC\18
and conduct
an
Steps.
ln
supervising this placement and investigating this report
of
child abuse and
neglect
as
required by State laws and regulations, DYFS policies and
p r o c e ~ u r e s as wei as any cotui 's orders that may have been in place.
23. As a direct and
r o x i n ~ t e
result of he foregoing breaches of duty of care y DYFS
and John Does (1"30), N had been and continued to be abused and neglected, and on
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November 21, 2009 Little assaulted N causing her to suffer severe injuries, pain and
suffering, disability and impailment, loss of enjoyment of life and death.
24. Defendant DYFS is vicariously liable for the wrongfitl acts and/or omissions
of
John Does (1-30) and/or ABC Entities (10-30) as its agents, servants, employees and/or
representatives whose conduct in tllis matter occurred within the scope
of
their·emp1oyment or
retention by DYFS.
WHEREFORE,· plaintiff Kamelia Turner, as Administrator d Prosequendum of the
Estate ofN A P T demands judgment against defendants, State ofNew Jersey,
Department
of
Children and Fanrilies, Division of Child Protection and e ~ m a n e n c y (formerly
known as the Division of Youth and Family Services), John Does
1 ~ 3 0 )
and/or ABC Entities (1-
30); jomtly and severally, pursuant
to
the New Jersey sui-0vorship Statute, N.J.SA. 2A:15-3, et.
§m., for compensatory damages, interest, att0ll1eys' fees, coSis of suit and such other relief as the
Court deems just and equitable.
SE OND
OUNT
25. Plaintiff repeats
all
the allegations pled in paragraphs
1
tlrrough 24 as though
fully set forth herein at length.
26. · t all times herein mentioned, the defendants State of New Jersey, Department of
Chlldren ~ d Families, Division of Child Protection imd Permanency, and/or ABC Entities (1-10)
h e r e i n a f t ~ r collectively referred to as DYFS ) had a duty to properly hire, train, screen, retain,'
and supervise its agents, ~ e r v a n t s , employees and/or representatives to ensme that they were
competent and properly providing those services as required by State .law, regulations, DYFS
. policies and procedures, andloi· any Court Orders issued to ensure the health,' safety, welfare and
protection ofchildren, including N
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27.
t
all times herein mentioned, DYFS
was
negligent and breached its aforesaid
duty
of carein
failing to properly hire, train, screen and supervise John Does (1-30) and/or
BC
Entities who were improperly and/or inadequately hired, trained, screened, retained and/or
supervised and. otherwise incompetent, and as a result they failed
to
fulfill their duties and
responsibilities to ensure the health, safety, welfare and protection ofN
28. As a direct and proximate result of the foregoing breaches of duty by DYFS, the
supervision
of N 's placement was improperly handled and the rep01t of child abuse and
neglect of N was improperly investigated
Uld
responded to, the result of which was that
N had been and continued to be abused and .neglected.
On
November 21, 2009 Little
assaulted N causing her
to
suffer severe injuries, pain and suffering, disability and
impairment, loss of enjoyment of life and death.
WIIEREFORE, pliintilr Kamelia Turner, as Adffiinistrator Ad Prosequendum
of
the
Estate ofNevaeh Anaisa Paris Turner demands judgment against defendants, State
of
New Jersey,
Department of Children and Families, Division of Child Protection and Permanency (formerly
known
s
the Division
of
Youth'and Family Services), and
BC
Entities (1-30), jointly and
severally, pursuant
to
ihe New Jersey Survivorship Statute, N.J.S.A. 2A:l5-3,
et. ~ .
for
compensatory damages, interest, attorneys'
:tees,
costs
of
suit and such other relief
as
the Court
deems just and equitable.
THIRD OUNT
29.-
Plaintiffrep.eats all
the
allegations pled
in
paragraphs
1
through
28 as
though
fully set forth herein
.at .Jength.
3 0. As a direct and proximate result of the defendants' negligence, :Kamelia Turner and
other heirs ofN have suffered, and will continue to suffer in the future, from the loss of the
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care, comfort, advice, companionship, consortium, and economic and emotional .snppmt of
Nevaeh.
WHEREFORE, plaintiff Kamelia Tnrner, as Administrator Ad Prosequendnrn of the
Estate ofN A P T demands judgment against defendants, State of ew Jersey,
Department of Children and Families, Division of Child Protection and Permanency (fmmerly
known as the Division ofYouth and Family Services), John Does (1-30) and ABC Entities (1-30),
jointly and severally, piu·suant to the New Jersey Wrongful Deaih Act, }u s A 2A:5i-1,
et ~ .
for compensatory damages, interest, attorneys' fees, costs of suit and such other relief as the Court
deems just and equitable.
JURY DEMAND
Plaintiff hereby demands a trial
by
jury on all isshes so triable.
DESIGNATION
OF
TRIAL COUNSEL
David A Mazie, Esq. and Beth G Baldinger are liereby designated as trial cmmsel in
this matter.
DEMAND
FOR ANSWERS
TO UNIFORM
INTERROGATORIES
Plaintiffs hereby demand that defendants provide certified atJswers'to Unifonn C
Interrogatories in accordance with
_R
4:17-1 (b)
of
the
ew
Jersey Rules
of
Comt.
DEM ANn FORJNSURANCE
COVERAGE
In accordance with
R
4:10-2, defendants mjlst provide complete copies of their
i n s ~ u c e policies and declaration sheets demonstrating coverage within thirty (30) days of
service of this Cmnplaint.
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RULE 4:5-1 CERTlFIC TION
I hereby certify that to the best of my knowledge the mattedn
conh Oversy
is not the
subject of any action pending in any court or of a pending arbitration proceeding. I hereby
certifY that the foregoing statements made by me are tme. I am aware. that if any of the
foregoing statements made by me are willfl.llly false, I am subject to punishment.
Dated: prill
0,
2015
MAZIE
SL TER
KATZ FREEMAN, LLC
Attorneys for Plaintiff
B Y ~ ~ t ? ~
BETH
G.
BALDINGER
I-1:\DAM\T , N Complaint Final)
4 ~ 1 0 ~ 1 5 d o c x
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Appendix XII-Bl
CIVIL CASE INFORMATION STATEMENT
(CIS)
FOR USE BY CLERI<'S
OFfiCE
ONLY
PAYI'ENTTYPE: OcK Oco
OcA
CHG/CKNO.
Use
for initial
Law
Division
AMOUNT
Civil Part pleadings (not motions) under
Rule 4:5-1
Pleading will be rejected
for
filing, under Rule 1 5-6(
c),
if
Information above the black
bar
is
not
completed
o1: attorney's signature is not affixed
OVERPAYMENT:
BATCH NUMBER:
AnORNEY I PROSE
NAME
Beth G. Baldinger, Esq.
FIRM
NAME (If applicable)
Mazie Slater Katz Freeman, LLC
OFFICE ADDRESS
103 Eisenhower Parkway
Roseland,
New
Jersey 07068
NAME
OF
PARTY (e.g., John Doe
PlainllfQ
Kamella Turner, as Administrator ad
Prosequendum of the Estate
of
N
T
TElEPHONE
NUMBER
(973) 228-9898
CAPTION
COUNTY OF
VENUE
Essex
DOCKET
NUMBER when
available}
L--::t5 -
DOCUMENTTY
Complaint
JURY
DEMAND
181
YES
0
No
l<amelia
Turner
as Administrator ad
Prosequendum of
the Estate of
N A P T , deceased, v State
of New
Jersey,
et
al.
CASE TYPE NUMBER
(See
reverse
side for Jrsling
HURRICANE SANDY
RELATED? IS THIS A PROFESSIONAL MALPRACTICE CASE?
0 YES 18 NO
605,699
0 YES t8j NO
RELATED CASES PENDING?
D
YES 181 NO
DO
YOU ANTICIPATE ADDING ANY PARTIES
(arising
out
of same
ransacUon or
ocx:urrence)?
DYEs
181
No
IF YOU HAVE CHECKED YES,
SEE N J S A 2A:53
A
-27 AND
APPLICABLE
CASE
LAW
REGARDING
YOUR
OBLIGATION
TO
FILE
AN
AfFIDAVIT OF MERIT.
IF
YES,
LIST DOCKET
NUMBERS
'··
NAME OF DEFENDANT'S PRIMARY INSURANCE COMPANY
(If
known)
D NoNE
t8j
UNKNOWN
THE
INFORMATION
PROVIDED
ON
THIS
FORM
CANNOT BE
INTRODUCED INTO EVIDENCE.
CASE
CHARACTERISTICS
FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
DO
PARTIES HAVE A
CURRENT,
PAST
OR
IF YES, IS THATRELAIIONSHIP:
RECURRENT RELATIONSHIP?
BIPLOYERfEMPLOYEE
D FRIEND/NEIGHBOR 181
OTHER
(explain)
181
YES
0
No
D
FNioiUAL
D
BUSINESS
DYFS
DOES
THE STATUTE
GOVERNING THIS CASE
PROVIDE FOR
PAYMENT OF FEES BYTHE LOSING
PARTY?
DYES
D
NO
USE
THIS SPACE
TO ALERTTHE COURT
TO ANY SPECIAL
CASE CHARACTERISTICS
THAT
MAY
WARRANT
N p ] , V I 9 U \ I ~ t 0 A N A G E M E N T oR'
ACCELERATED DISPOSITION
t .., . •
...
·
Claims against
State
of
New Jersey, Division
of
Child Protection
and
Permanency fo nieffy DlVIsiO'h 'OIYOU11i'iipd
Farnlly
Services)
for negligence resulting in
the wrongful
death
of
a child. • :
i
~ F l i l l
n
a®t»J
:
i
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NEEDED?
IF
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FOR
WHAT
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DYES
181
No
f certify that confldentfal
personal
identifiers have been redacted from documents now submitted to the
court,
and
will
be
redacted
from all documents submitted
in
the future
fn
accordance with
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DORNEY
SIGNATURE:
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Effective 0 8 ~ 1 9 - 2 0 1 3
CN
10517-Engllsh
page
1 of2
7/23/2019 Turner v NJ Dept of Children and Families
http://slidepdf.com/reader/full/turner-v-nj-dept-of-children-and-families 14/14
CIVIL CASE INFORMATION STATEMENT
(CIS)
Use
for initial
pleadings
not motions) under ule
4:5-1
CASE TYPES
Choose
one and
enter number of
case
type
In
appropriate
space
on
the
reverse
side.)
Track I R
150 days' discovery
151 NAME
CHANGE
175 FORFEITURE
302 TENANCY
399 REAL
PROPERTY
{other than Tenancy,
Contract,
Condemnation, Complex Commercial or Constructlon)
502
BOOK
ACCOUNT
(debt collection maHers only)
505 OTHER INSURANCE CLAIM (Including declaralmy judgment actions)
506 PIP COVERAGE
510 UM or U M
CLAlM
coverage
Issues only)
511
ACTION ON NEGOTIABLE INSTRUMENT
512 LEMON LAW
601
SUMMARY ACTION
802
OPEN PUBLIC RECORDS
ACT (summary acllon)
999
OTHER {briefly
describe
nature
of aclion)
Track
II
R
300
days'
discovery
305 CONSTRUCTION
509 EMPLOYMENT (olher th n
CEPA
or LAD)
599
CONTRACT/COMMERCIAL TRANSACTION
603N AUTO NEGLIGENCE- PERSONAL INJURY (non-verballhreshold)
603Y AUTO NEGLIGENCE-
PERSONAL
INJURY verbal threshold)
605 PERSONALINJURY
610 AUTO NEGLIGENCE- PROPERTY DAMAGE
621 UM or UIM CLAIM Includes bodily Injury)
699
TORT
OTHER
Track Ill • 450 days discovery
005 CIVIL RIGHTS
301 CONDEMNATION
602 ASSAULT AND BATTERY
604 MEDICAL MALPRACTICE
606 PRODUCT LIABILITY
607 PROFESSIONAL MALPRACTICE
608 TOXIC TORT
609 DEFAMATION
616 WHISTLEBLOWER/ CONSCIENTIOUS
EMPLOYEE
PROTECTION ACT
CEPA) CASES
617 INVERSE CONDEMNATION
618 LAW AGAINST DISCRIMINATION LAD)
CASES
Track IV • Active Case Management by Individual Judge /450 days discovery
156 ENVIRONMENTAUENVlRONMENTAL COVERAGE LITIGATION
303 MT.
LAUREL
508 COMPLEX COMMERCIAL
513 COMPLEX CONSTRUCTION
514 INSURANCE FRAUD
620 FALSE CLAIMS ACT
701
ACTIONS
IN
LIEU OF PREROGATIVE WRITS
Multicounty Litigation (Track
IV)
266 HORMONE REPLACEMENT THERAPY
HRT) 288
PRUDENTIAL TORT LITIGATION
271 ACCUTANEIISOTRETINOIN 289
REGLAN
274 RISPERDAUSEROQUEUZVPREXA 290 POMPTON LAKES ENVIRONMENTAL LITIGATION
276 ZOMETNAREDIA
291
PELVIC MESHIGYNECARE
279 GADOLINIUM
292
PELVIC MESH/BARD
281
BRISTOL-MYERS SQUIBB ENVIRONMENTAL
293
DEPUY ASR HIP IMPLANT LITIGATION
282 FOSAMAX 295 ALLODERM REGENERATIVE TISSUE MATRIX
284 NUVARING 296 STRYKER REJUVENATE/ABO II MODULAR HIP STEM COMPONENTS
285
STRYKER
TRIDENT HIP IMPLANTS 297
MIRENA
CONTRACEPTIVE DEVICE
286 LEVAQUIN 601 ASBESTOS
287 YAZ/YASMIN/OCELLA
623
PROPECIA
f
you believe tills case requires \ track other
than that
provided above, please Indicate the reason on Side 1,
in
tho
space under "Case Characteristics.
lease check off each applicable category 0 Putative Class ction
0 Tille 59
Effec ive 08-19-2013 GN
10517-Engl sh
page of