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Ty Hyderally, Esq. (ID# 023231993)
HYDERALLY & ASSOCIATES, P.C.
33 PLYMOUTH STREET
SUITE 202
MONTCLAIR, NEW JERSEY 07042
TELEPHONE (973) 509-8500
FACSIMILE (973) 509-8501
Attorneys for Plaintiff: Gretchen McCarthy
GRETCHEN MCCARTHY, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: MONMOUTH COUNTY
PLAINTIFF, DOCKET NO.:
VS. CIVIL ACTION
BOROUGH OF ENGLISHTOWN, CHIEF
OF POLICE, PETER COOKE, JR., COMPLAINT AND JURY DEMAND
INDIVIDUALLY AND IN HIS OFFICIAL
CAPACITY, JOHN DOES 1-10, AND XYZ
CORP. 1-10,
DEFENDANTS.
Plaintiff, Gretchen McCarthy (“Ms. McCarthy” or “Plaintiff”), who resides at 182 Federal
Road, Monroe Township, New Jersey 08831, by way of this Complaint against Defendants,
Borough of Englishtown (the “Borough”), Chief of Police Peter Cooke, Jr. (“Chief Cooke”),
individually and in his official capacity, John Does 1-10, and XYZ Corp. 1-10 (hereinafter,
collectively “Defendants”), hereby says:
I. Nature of Action, Jurisdiction, and Venue
1. This is an action seeking equitable and legal relief for: (1) a violation of the Conscientious
Employee Protection Act, N.J.S.A. 34:19-1, et seq. (“CEPA”); (2) a violation of the New
Jersey Law Against Discrimination, N.J.S.A. 10:5-1 et seq. (“LAD”) (Disability
Discrimination); and (3) a violation of the LAD (Retaliation).
2. This court has jurisdiction due to the nature of the action and the amount in controversy.
Additionally, Plaintiff has satisfied all prerequisites to bringing these claims.
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3. Venue is appropriate in this court since Plaintiff worked in Monmouth County during the
relevant time period, the Defendants have a place of business in Monmouth County, and
some or all of the causes of action accrued in Monmouth County, New Jersey.
II. Parties
4. During the relevant time period, Ms. McCarthy was an employee of the Borough and
worked in the State of New Jersey.
5. The Borough is municipality with a business address at 15 Main Street, Englishtown, New
Jersey 07726.
6. During the relevant time period, Chief Cooke was the Chief of Police for the Borough.
7. Thus, during the relevant time period, Chief Cooke was a member of management who
controlled Plaintiff’s workplace and supervised Plaintiff and (1) aided the employer in
performing a wrongful act that caused an injury; (2) was generally aware of his role as part
of an illegal or tortious activity at the time he provided assistance; and (3) knowingly and
substantially assisted the employer in the principal violation of the statutes referenced
herein.
8. During the relevant time period, JOHN DOES 1-10 are currently unknown employees who
were either senior management level employees who controlled Plaintiff’s workplace, and
supervised Plaintiff and aided and/or abetted in the commission of conduct complained of
herein and/or who either acted within the scope of their employment at the workplace
during working hours, or, to the extent they went beyond the scope of their employment,
defendants ratified, embraced and added to this conduct. As the parties engage in
discovery, Plaintiff retains the right to amend the Complaint to add these individual
employees by name.
9. During the relevant time period, XYZ Corp. 1-10 are unknown affiliated corporations or
entities or other corporations who have liability for the claims set forth herein. As the
parties engage in discovery, Plaintiff retains the right to amend the Complaint to add these
individual entities by name.
10. Thus, all the defendants are subject to suit under the statutes alleged above.
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11. At all times referred to in this Complaint, employees of the Borough, who are referred to
herein, were acting within the scope of their employment at the workplace during working
hours, or, to the extent that they were not so acting, the corporate defendants ratified,
embraced and added to their conduct.
III. Factual Allegations
12. On or about May 4, 2021, Ms. McCarthy began working for the Borough as Deputy
Municipal Clerk.
13. At all times material herein, Ms. McCarthy performed her duties in an exemplary fashion
and consistently met or exceeded all of Defendants’ legitimate expectations.
14. Ms. McCarthy’s duties included, but were not limited to: serving as the Borough’s
Custodian of Records and receiving and responding to requests made pursuant to the Open
Public Records Act (“OPRA”); receiving monies for licenses and services provided by the
Clerk’s Office and providing receipts for those payments when necessary; registering all
Borough vehicles with the New Jersey Motor Vehicles Commission (“MVC”); and
swearing in police officers who were appointed to the Borough.
15. In October 2021, the former Municipal Clerk, Peter Gorbatuk, advised that he was not
returning to the Borough, and, thus, Ms. McCarthy was appointed as the Borough’s
Municipal Clerk/Registrar of Vital Statistics in January 2022.
16. Thus, Ms. McCarthy became the sole person permanently responsible for the Municipal
Clerk’s office as well as the Vital Statistics department.
17. In mid-January 2022, Ms. McCarthy received an email from Chief Cooke requesting that
a resolution be placed on the January 26, 2022, council meeting agenda to authorize the
purchase of a specific police vehicle without providing any specifications, which is
required under N.J.A.C. 5:34-7.7(b).
18. Ms. McCarthy objected and requested the mandatory specifications so that she could
prepare the resolution.
19. Subsequently, Ms. McCarthy took note that the requested quote from Beyer Fleet had a
contract number that began with “ESCNJ.”
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20. For the contract to be legally valid, Beyer Fleet had to be an approved vendor with the
ESCNJ to sell police vehicles to the Borough, per N.J.A.C. 5:34-7.6(a).
21. Ms. McCarthy discovered that Beyer Fleet was not an approved vendor.
22. Thus, Ms. McCarthy objected to preparing the resolution during this mid-January 2022
time period.
23. On May 17, 2022, Chief Cooke demanded that Ms. McCarthy provide the mandatory
specifications that she had earlier requested from him.
24. Ms. McCarthy objected to Mayor Thomas Reynolds (“Mayor Reynolds”) who
begrudgingly agreed that she should get Chief Cooke to provide the information.
25. When Ms. McCarthy informed Chief Cooke of this, he contacted the Police Commissioner,
Eric Mann (“Commissioner Mann”) who accused Ms. McCarthy of intentionally delaying
the process to purchase the police vehicle and noted that that Chief Cooke was extremely
unhappy with Ms. McCarthy.
26. Ms. McCarthy advised that she was merely following state regulations and wanted to
ensure that everything was done in a proper and legal manner.
27. Finally, Beyer Fleet submitted an appropriate revised quote that was approved at the June
22, 2022, council meeting.
28. On November 10, 2022, Ms. McCarthy sent a formal whistleblower complaint to
Defendants. (Exhibit “1”).
29. In that complaint, Ms. McCarthy noted that Chief Cooke, was directing people to the
Municipal Clerk/Vital Statistics offices, to get receipts for monies that they gave to the
Borough Police Department.
30. Normal practice was that the Borough Police Department issued its own receipts when it
accepted payments, as no one in Vital Statistics would know the basis for the request for
receipts, what people were paying for, whether the payment was legitimate, or why they
were asked to make payment to the police department.
31. Ms. McCarthy objected to the practice to Chief Cooke who demanded that McCarthy just
do as he directed.
32. Ms. McCarthy noted that she escalated her complaint in February 2022 to the Mayor and
the Borough Councilmembers.
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33. Additionally, Ms. McCarthy informed Mayor Reynolds that she would like to hear from
the Borough Auditor, Robert Allison (“Mr. Allison”), about whether this process that Chief
Cooke demanded she engage in was legal.
34. Although Mayor Reynolds stated that he would have Mr. Allison contact Ms. McCarthy,
Mr. Allison never contacted her.
35. In or about February or March 2022, Ms. McCarthy refused to write a receipt for funds
purportedly received by the Police Department, after which Chief Cooke burst into Ms.
McCarthy’s office to confront Ms. McCarthy about her refusal.
36. Ms. McCarthy informed Chief Cooke that she needed to ensure that if she was going to
issue a receipt, she needed to ensure the receipt was legitimate and accurate and she needed
to further ensure that the payments that people were making to the police department was
legitimate.
37. Chief Cooke responded that this was always the way things were done and demanded that
Ms. McCarthy continue to issue the requested receipts.
38. During this same time period, Ms. McCarthy complained about the Police Department’s
frequent practice of violating OPRA by not responding to OPRA requests within seven (7)
business days, as is mandated by OPRA.
39. However, no curative or remedial action was taken.
40. Further, when citizens went to the Police Department to get a copy of their motor vehicle
accident report, Chief Cooke informed members of the Police Department to send those
citizens to the Municipal Office to make an OPRA request.
41. N.J.S.A. 39:4-131 allows citizens to inspect, copy, and obtain motor vehicle accident
reports, without having to make an OPRA request.
42. Ms. McCarthy also objected to this illegal activity.
43. Once again, no remedial or curative action was taken.
44. During this same time period that Ms. McCarthy was objecting to the numerous illegal
actions that were occurring, the Chief of Police suddenly insisted that she fill out the
Background Check Questions that she had never filled out before and that she had never
previously been even asked to fill out.
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45. Ms. McCarthy reviewed the paperwork and realized that the form requested very detailed,
private information.
46. In addition to having her fingerprints taken, Chief Cooke was forcing Ms. McCarthy to
divulge information including, but not limited to, her height, weight, race, ethnicity, sex at
birth, current sex, any tattoos or scars, and any cars she owned, and to provide signed
authorizations for the release of banking records, health care records, credit agency
reporting information, and all government agency records.
47. Ms. McCarthy was very alarmed at the overly invasive request for information, and voiced
her objections regarding the background check to the Borough Attorney, Joseph Youssouf,
Esq. (“Mr. Youssouf”) who did not reply.
48. Despite her concerns about the overly invasive questions, Ms. McCarthy moved forward
with completing the background check and, on March 19, 2022, scheduled an appointment
and had her fingerprints taken on April 23, 2022. (Composite Exhibit “2”).
49. After reviewing the background check questionnaire thoroughly, Ms. McCarthy sought and
reviewed the Borough’s ordinances, and found the Borough of Englishtown Ordinance No.
2006-17, which took effect January 1, 2007. (Exhibit “3”).
50. Ms. McCarthy took note that the only time Borough employees were required to submit to
a background check was when they worked with children.
51. Further, even in those situations, it was only a criminal background check.
52. Additionally, the only consequence of refusing to submit to such a background check is
that the employee is precluded from working with children. Borough of Englishtown
Ordinance No. 2006-12, at ¶1.28.03D.
53. Ms. McCarthy complained to Mr. Gregory Wojyn, Council President, Mr. Youssouf, and
Commissioner Mann about the retaliatory demands made by Chief Cooke.
54. In a March 30, 2022, email, Mr. Youssouf agreed that, “Such highly personal questions are
highly inappropriate for a potential employee who is not a candidate for the police
department,” and further stated that, “The background check should include the applicant’s
social security number, fingerprints and social security number only.” (Exhibit “4”).
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55. Despite this, Chief Cooke and Detective Corporal Alexander DiNicola continued their
campaign of retaliation and harassment against Ms. McCarthy, regularly, emailing Ms.
McCarthy regarding the criminal background check.
56. Ms. McCarthy renewed her objections to Mr. Youssouf and the issue was discussed at the
following Borough council meeting, which occurred on April 27, 2022.
57. Due to the continuing retaliatory pressures, Ms. McCarthy did submit to her fingerprints
being taken on April 23, 2022.
58. At the Borough Council’s April 27, 2022, meeting, the Council agreed that the Borough
Attorney would revise the background check form.
59. Despite the fact that the form was not revised, Chief Cooke continued to insist that Ms.
McCarthy provide the highly personal information and authorization.
60. On August 24, 2022, Ms. McCarthy informed Mayor Reynolds and the Borough Council
that due to her disabling medical condition, she needed to have surgery and take a medical
leave of absence from November 10, 2022, to December 26, 2022.
61. Defendants expressed concerns over who would cover the office and offered no words of
sympathy related to Ms. McCarthy’s medical situation.
62. Ms. McCarthy apologized for the inconvenience but noted that it was a medically necessary
surgery as she was having difficulty walking and sleeping due to her disabling hip
condition.
63. Because Defendants continued to harass and retaliate Ms. McCarthy subsequently, she
formalized her whistleblower complaint in a November 10, 2022 email that was sent to
Council Members, Chief Cooke, Mayor Reynolds, and others.
64. Ms. McCarthy noted that many of the questions in the Background Check Questions were
invasive of her privacy and in no way related to any reasonable need by the Borough to be
answered.
65. Defendants failed to respond to her complaint.
66. Defendants took no action to investigate the complaint.
67. Ms. McCarthy then took a medical leave of absence from November 10, 2022, that was
subsequently extended from December 26, 2022, to January 9, 2023.
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68. As noted above, the surgery was medically necessary as Ms. McCarthy was enduring
inordinate pain to engage in the essential life functions of sleeping and walking, due to her
debilitating hip condition.
69. On or about January 5, 2023, Mayor Reynolds called Ms. McCarthy and asked if she would
be returning from her medical leave on January 10, 2023, as the Borough Council would
be holding its reorganization meeting that night.
70. Ms. McCarthy replied that she would be returning to work that day, but informed Mayor
Reynolds that the Borough Council was required to hold its annual reorganization meeting
within the first seven days of the year. N.J.S.A. 40A:60-3 and N.J.S.A. 40:45A-1.
71. Nonetheless, Mayor Reynolds insisted that the meeting would be held on January 10, 2023.
72. At its January 10, 2023, meeting, the Borough Attorney asked Ms. McCarthy whether she
had filled out the background check form, and Ms. McCarthy answered that she had made
written objections but had received no reply.
73. The Borough Attorney then stated that this was cause for immediate dismissal.
74. Defendants then terminated Ms. McCarthy, effective January 10, 2023, her first date back
to work following her disability leave.
75. Defendants ignored Ms. McCarthy’s request for more information.
76. Defendants ignored its own Attorney’s acknowledgment that the demands they were
making of Ms. McCarthy were not proper or legal.
77. Defendants ignored that certain Borough employees did not fill out the forms and/or did
not fully fill out the forms.
78. Defendants ignored the fact that there were lesser forms of discipline available to them
then terminating Ms. McCarthy.
79. Defendants ignored the fact that the meeting that was held to terminate her was an illegal
meeting.
80. Prior to engaging in whistleblowing activities, Ms. McCarthy had never received any
warnings about her performance.
81. Prior to engaging in whistleblowing activities, Ms. McCarthy had never been written up.
82. Prior to engaging in whistleblowing activities, Ms. McCarthy had never been disciplined.
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83. Defendants never put Ms. McCarthy on a performance improvement plan regarding her
performance, before they terminated Ms. McCarthy.
84. Defendants’ termination of Ms. McCarthy is clearly not based upon any legitimate reasons,
but rather, is in retaliation for Ms. McCarthy’s whistleblowing activities and in retaliation
for her taking a disability leave of absence.
85. After her termination, Ms. McCarthy’s job duties were assumed by other employees who
did not engage in whistleblowing activities and other employees who had not just recently
taken a disability leave.
86. Ms. McCarthy has suffered and continues to suffer severe emotional distress, physical
injury, and/or the physical manifestation of emotional distress damages, anxiety and
sleeplessness due to Defendants’ retaliation and termination.
87. At the time of her termination, Ms. McCarthy was employed as the Borough’s Municipal
Clerk/Registrar of Vital Statistics, at a rate of pay of approximately seventy thousand
dollars ($70,000.00) per year.
88. Further, McCarthy received benefits of employment, including a pension, paid vacation of
4 weeks per year, 12 sick days, 3 personal days, and 14 paid holidays, and was eligible for
other benefits, including medical benefits, dental benefits, vision benefits, life insurance,
short term disability insurance, and long term disability insurance.
89. These benefits of employment make up McCarthy’s claim for damages.
Count I
(CEPA)
90. Plaintiff realleges and incorporates herein the paragraphs set forth in this Complaint, unless
noted below.
91. First, Plaintiff reasonably believed that Defendants conduct was violating either a law,
regulation, or a clear mandate of public policy by failing to respond timely to OPRA
requests, by requiring McCarthy to provide receipts for funds which she did not in fact
receive, by requiring individuals to complete OPRA requests to receive copies of their own
motor vehicle accident reports, by attempting to purchase a vehicle without proper
authorization, and by failing to register motor vehicles with the New Jersey Motor Vehicle
Commission.
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92. Second, Plaintiff objected to Defendants’ unlawful conduct and disclosed the unlawful
conduct to Defendants in numerous communications to Defendants.
93. Plaintiff also objected to Defendants’ requirement that McCarthy fill out a highly invasive
and inappropriate background check, in retaliation for McCarthy’s whistleblowing
complaints.
94. Third, Plaintiff suffered an adverse employment action.
95. Rather than take curative action, Defendants retaliated against McCarthy for objecting to
Defendants’ illegal practices by terminating McCarthy on January 10, 2023. This
retaliatory act by Defendants creates and satisfies the specific factual predicate for the
CEPA violation alleged herein.
96. Fourth, Defendants retaliated against Plaintiff because Plaintiff did one or more of the
following:
(a) Disclosed or threatened to disclose to a supervisor or a public body an activity,
policy or practice of the employer or another employer, with whom there is a
business relationship, that the Plaintiff reasonably believed is in violation of a law,
or a rule or regulation promulgated pursuant to law;
(b) Provided information to, or testified before, any public body conducting an
investigation, hearing or inquiry into any violation of law, or a rule or regulation
promulgated pursuant to law by the employer or another employer, with whom
there is a business relationship; or
(c) Objected to, or refused to participate in an activity, policy or practice which
Plaintiff reasonably believed:
(i) is in violation of a law, or a rule or regulation promulgated pursuant to law;
or
(ii) is fraudulent or criminal; or
(iii) is incompatible with a clear mandate of a public policy concerning the
health, safety, or welfare or protection of the environment.
97. The above actions of Defendants demonstrate that they are in violation of CEPA.
98. The facts supporting the CEPA violation are separate and distinct from the facts supporting
the other claims pled in this Complaint.
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99. As a direct and proximate result of the actions of Defendants, Plaintiff has suffered mental
anguish, physical discomfort, pain and suffering, shame and embarrassment, emotional
distress injuries, the physical manifestation of emotional distress injuries and/or physical
injury. Furthermore, Plaintiff has suffered lost wages, a diminished ability to earn a living,
and a diminished capacity to enjoy Plaintiff’s life. Moreover, Plaintiff has and/or may have
to incur expenses for medical, psychiatric, and/or psychological counseling and care.
Plaintiff’s damages have been experienced in the past, and they will continue into the
future.
100. Further, Plaintiff has been required to retain an attorney to assist Plaintiff in
asserting Plaintiff’s claims and protecting Plaintiff’s rights.
Count II
(LAD)
(Disability/ Handicap Discrimination)
101. Plaintiff realleges and incorporates herein the paragraphs set forth in this
Complaint.
102. The foregoing facts and circumstances demonstrate that Defendants have violated
the New Jersey Law Against Discrimination, N.J.S.A. 10:5-1 et seq., by discriminating
against Plaintiff due to Plaintiff’s handicap and/or disability.
103. As a direct and proximate result of the actions of Defendants, Plaintiff has suffered
mental anguish, physical discomfort, pain and suffering, shame and embarrassment,
emotional distress injuries, the physical manifestation of emotional distress injuries and/or
physical injury. Furthermore, Plaintiff has suffered lost wages, a diminished ability to earn
a living, and a diminished capacity to enjoy Plaintiff’s life. Moreover, Plaintiff has and/or
may have to incur expenses for medical, psychiatric, and/or psychological counseling and
care. Plaintiff’s damages have been experienced in the past, and they will continue into
the future.
104. Further, Plaintiff has been required to retain an attorney to assist Plaintiff in
asserting Plaintiff’s claims and protecting Plaintiff’s rights. Plaintiff realleges and
incorporates herein the paragraphs set forth in this Complaint.
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Count III
(LAD)
(Retaliation)
105. The foregoing facts and circumstances demonstrate that Defendants have violated
the New Jersey Law Against Discrimination, N.J.S.A. 10:5-1 et seq., by retaliating against
Plaintiff for engaging in the protected activity of taking disability leave and/or medical
leave and/or requesting reasonable accommodations due to the medical/disability leave.
106. As a direct and proximate result of the actions of Defendants, Plaintiff has suffered
mental anguish, physical discomfort, pain and suffering, shame and embarrassment,
emotional distress injuries, the physical manifestation of emotional distress injuries and/or
physical injury. Furthermore, Plaintiff has suffered lost wages, a diminished ability to earn
a living, and a diminished capacity to enjoy Plaintiff’s life. Moreover, Plaintiff has and/or
may have to incur expenses for medical, psychiatric, and/or psychological counseling and
care. Plaintiff’s damages have been experienced in the past, and they will continue into
the future.
107. Further, Plaintiff has been required to retain an attorney to assist Plaintiff in
asserting Plaintiff’s claims and protecting Plaintiff’s rights.
WHEREFORE, as to each and every count, Plaintiff demands judgment on each and all of these
Counts against the Defendants jointly and severally, as follows:
A. Compensatory damages of not less than $250,000.00;
B. Damages for lost wages and benefits, back pay, front pay (or reinstatement);
C. Damages for humiliation, mental and emotional distress;
D. Statutory damages, if applicable;
E. Punitive damages and or liquidated damages where permitted by law;
F. Attorneys' fees and costs of suit;
G. Lawful interest including pre-judgment interest on lost wages;
H. Lawful interest - including pre-judgment interest on any wages not paid in a timely
manner; and
I. Such other, further and different relief as the Court deems fitting, just and proper.
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Plaintiff hereby reserves the right to amend this Complaint to supplement or modify the factual
obligations and claims contained herein, based upon information received from the defendants,
witnesses, experts, and others in the course of discovery in this matter.
DEMAND FOR TRIAL BY JURY
Pursuant to Rule 4:35-1(a) and (b), Plaintiff respectfully demands a trial by jury on all
issues in the within action so triable.
DESIGNATION OF TRIAL COUNSEL
In accordance with Rule 4:25-4, TY HYDERALLY is hereby designated as trial counsel
on behalf of Plaintiff.
R. 4:5-1(b)(2) CERTIFICATION OF NO OTHER ACTIONS OR PARTIES
I hereby certify that the matter in controversy is not the subject of any other action pending
in any court or of a pending arbitration proceeding, that no other action or arbitration proceeding
is contemplated, and that there are no other parties known to me at this time who should be joined
as parties to this action.
DEMAND FOR PRODUCTION OF INSURANCE AGREEMENTS
Pursuant to R. 4:10-2(b), demand is hereby made that you disclose to the undersigned
whether there are any insurance agreements or policies under which any person or firm carrying
on an insurance business may be liable to satisfy all or part of a judgment which may be entered
in the action or to indemnify or reimburse for payment made to satisfy the judgment.
If so, please attach a copy of each, or in the alternative state, under oath and certification:
(A) policy number; (b) name and address of insurer; (c) inception and expiration date; (d) names
and addresses of all persons insured thereunder; (e) personal injury limits; (f) property damage
limits; and (g) medical payment limits.
DATED: November 9, 2023 HYDERALLY & ASSOCIATES, P.C.
Attorneys for Plaintiff
By:__________________________________
TY HYDERALLY, Esq.
For the Firm
T:\McCarthy Gretchen\Pleadings\110923.COM.docx
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Exhibit “1”
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Exhibit “2”
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Exhibit “3”
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Exhibit “4”
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Civil Case Information Statement
Case Details: MONMOUTH | Civil Part Docket# L-003567-23
Case Caption: MCCARTHY GRETCHEN VS BOROUGH Case Type: LAW AGAINST DISCRIMINATION (LAD) CASES
OF ENGLISHTO WN Document Type: Complaint with Jury Demand
Case Initiation Date: 11/09/2023 Jury Demand: YES - 6 JURORS
Attorney Name: TY HYDERALLY Is this a professional malpractice case? NO
Firm Name: HYDERALLY & ASSOCIATES, P.C. Related cases pending: NO
Address: 33 PLYMOUTH ST STE 202 If yes, list docket numbers:
MONTCLAIR NJ 07042 Do you anticipate adding any parties (arising out of same
Phone: 9735098500 transaction or occurrence)? NO
Name of Party: PLAINTIFF : McCarthy, Gretchen Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): Unknown Are sexual abuse claims alleged by: Gretchen McCarthy? NO
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 recurrent relationship? YES
If yes, is that relationship: Employer/Employee
Does the statute governing this case provide for payment of fees by the losing party? YES
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
Do you or your client need any disability accommodations? NO
If yes, please identify the requested accommodation:
Will an interpreter be needed? NO
If yes, for what language:
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)
11/09/2023 /s/ TY HYDERALLY
Dated Signed
