.

~~---~-----~

MAZIE SLATER KATZ & FREEMAN, LLC

Beth G. Baldinger (Attorney ID# 032681985)
103 Eisenhower Parkway
Roseland, New Jersey 07068
(973) 228-9898
Attorneys for Plaintiffs
KAMELIA TURNER, as Administrator Ad
Prosequendum of the Estate ofN
A
P
T
, deceased

1\!1'
~~u".

nill. 2a1"
.. \m1 :

. .:.:.----.
:.!
' ....
;
-.;: ;

... :

'~

~-

.-:./:.

SUPERIOR COURT OF NEW JERSEY

LAW DIVISION: ESSEX COUNTY
DOCKET NO.: ESX-L- 'J...$}.}f-f.5

Plaintiff,

CIVIL ACTION

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,

COMPLAINT AND JURY DEMAND

_ _ _ Defendants.
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.
ofNe

At all relevant timeS herein, plaintiff Kamelia Turner ("Turner").was the mother
.Anaisa P

("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.

2.

At 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.

FACTS
4.

From approximately May of 2007 through June of 2009, when N

was 6

mon1hs old through 2 Yz 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 in Pennsylvania

and her foster family was seeking to adopt her.

In or around 2008 and early 2009, DYFS and John Does (1-10) conducted

5,
paternity

!~sting and con:fi1med that Tamir Little was N

's biological father and sought to

have him provide support for N

6. .
custody ofN

In or ~ound 2008 and early20.09, DYFS and John Does (1-30) took action to have
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.

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,

Irvin~on, 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'sJune 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

requhing 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 of the b\lffiS to her hand and r~ferral 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 trunk
a
k, which l)e suspected were due to physical abuse.
.
Dr. AdeWtmmi noted that N

's demeanor was guarded and afraid.

3

(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 of 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 of 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 qf N

,in this placement, and were

mandated to properly and promptly investigate the report of child abuse and neglect of 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

ce~ebral 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 of child abus~ and neglect.

!
i

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.
ofN

On March 12, 2013, Tamir Little pled guilty to manslaughter charges for the death
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 COUNT
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 of

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 th11t
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 afiaid; 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 of Jlme 30, 2009 through November 21, 2009, DYFS and

John Does (1-30) were under a mandatory duty to properly provide" services and supervision of
Ne

in this placement, and/or to follow the State laws, regulations, policies and procedures

which govemDYFS investigations of reports of child abuse and/or neglect, and were obligated to
5

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

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

since she

posed;

(f)
.. (g)

IdentifY the 'red flag' signs of abuse aqd/or neglect;

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

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
and the provision of services in tlus placement; and
supervision ofN
Otherwise act to protect and ensme the health, safety and welfare of
N

21.

's

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

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

John Does (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 of child 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 me not limited to the followiug:
(a)

, conduct a visual
Failure to periodically and/or promptly visit N
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)

(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;

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
prescribed by physicians who saw ht<r;

(c).

Failure to iuterview ~ll 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
at his exam on 09tober 5,
documentation as to his observations ofN
2009;

(d)

Failure to conduct initial and on-going safety and risk f\SSessments;

(e)

Failme 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 in N

' s case and to
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 all of

N
' s injmies, scars, suspicious marks and other conditions and all
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 of harm; 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)

23.

an

Otherwise failing to provide all serVJC\18 and conduct

Steps. ln
supervising this placement and investigating this report of child abuse and
neglect as required by State laws and regulations, DYFS policies and
proce~ures, as wei! as any cotui's orders that may have been in place.
As a direct and proxin~ate result of the foregoing breaches of duty of care by DYFS

and John Does (1"30), N

had been and continued to be abused and neglected, and on

8

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 theiremp1oyment or
retention by DYFS.
WHEREFORE, plaintiff Kamelia Turner, as Administrator Ad Prosequendum of the
Estate ofN

demands judgment against defendants, State of New Jersey,

Department of Children and Fanrilies, Division of Child Protection and

known as the Division of Youth and Family Services), John Does

Pe~manency (formerly

(1~30) 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.

SECOND COUNT
25.

Plaintiff repeats all the allegations pled in paragraphs "1" tlrrough "24" as though

fully set forth herein at length.

..
.
.
26. At all times herein mentioned, the defendants State of New Jersey, Department of

~d Families, Division of Child Protection imd Permanency, and/or ABC Entities (1-10)
(hereinaft~r collectively referred to as "DYFS") had a duty to properly hire, train, screen, retain,'
Chlldren

and supervise its agents,

~ervants,

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

27.

At 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 ABC
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
neglect of N
N

's placement was improperly handled and the rep01t of child abuse and
was improperly investigated !Uld responded to, the result of which was that

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

as the Division of Youth'and Family Services), and ABC 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 COUNT

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
10

care, comfort, advice, companionship, consortium, and economic and emotional .snppmt of
Nevaeh.
WHEREFORE, plaintiff Kamelia Tnrner, as Administrator Ad Prosequendnrn of the
Estate ofN

demands judgment against defendants, State of New Jersey,

Department of Children and Families, Division of Child Protection and Permanency (fmmerly
known as the Division of Youth and Family Services), John Does (1-30) and ABC Entities (1-30),
jointly and severally, piusuant 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 is shes 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 New Jersey Rules of Comt.

DEM.ANn FORJNSURANCE COVERAGE.

In accordance with R. 4:10-2, defendants mjlst provide complete copies of their

ins~auce policies and declaration sheets

demonstrating coverage within thirty (30) days of

service of this Cmnplaint.

11

"RULE 4:5-1 CERTlFICATION

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.

MAZIE SLATER KATZ & FREEMAN, LLC

Attorneys for Plaintiff

BY~--~t?~

BETH G. BALDINGER

Dated: Aprill 0, 2015

(I-1:\DAM\T

,N

Complaint (Final) 4~10~15.docx

I
12

Appendix XII-Bl
FOR USE BY CLERI<'S OFfiCE ONLY

CIVIL CASE INFORMATION STATEMENT

PAYI'ENTTYPE:

(CIS)
Use for initial Law Division
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
AnORNEY I PROSE NAME
Beth G. Baldinger, Esq.

OcK Oco OcA

CHG/CKNO.
AMOUNT!

OVERPAYMENT:
BATCH NUMBER:

TElEPHONE NUMBER

COUNTY OF VENUE

(973) 228-9898

Essex

FIRM NAME (If applicable)

Mazie Slater Katz & Freeman, LLC

DOCKET NUMBER (when available}

OFFICE ADDRESS
103 Eisenhower Parkway
Roseland, New Jersey 07068

DOCUMENTTY
Complaint

L--::t5

181

JURY DEMAND

YES

No

NAME OF PARTY (e.g., John Doe, PlainllfQ

CAPTION

Kamella Turner, as Administrator ad

Prosequendum of the Estate of
N
T

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)

605,699

HURRICANE SANDY
RELATED?
0 YES
t8j NO

RELATED CASES PENDING?

181

YES

181

18!

YES

NO

'

NO

DO YOU ANTICIPATE ADDING ANY PARTIES

(arising out of same !ransacUon or ocx:urrence)?
DYEs

IS THIS A PROFESSIONAL MALPRACTICE CASE?

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

No

THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE.

CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
IF YES, IS THATRELAIIONSHIP:
DO PARTIES HAVE A CURRENT, PAST OR
RECURRENT RELATIONSHIP?
0 BIPLOYERfEMPLOYEE
D FRIEND/NEIGHBOR
D FNioiUAL
D BUSINESS DYFS
181 YES
0 No
DOES THE STATUTE GOVERNING THIS CASE PROVIDE FOR PAYMENT OF FEES BYTHE LOSING PARTY?

181

OTHER (explain)

DYES

D NO

USE THIS SPACE TO ALERTTHE COURT TO ANY SPECIAL CASE CHARACTERISTICS THAT MAY WARRANT 1Np],VI9U\I~t0ANAGEMENT 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
~'Flill

......

16

. - . "~-- . '

DO YOU OR YOUR CLIEtff NEED NlY DJSABJUTY ACCOMMODATIONS?

l8l

DYES

181

.....

i
.._ __

'~

1 ,;

f...... ~- ........ ~----.---~. ....

.., . -

IF YES, FOR WHAT lANGUAGE?

Wl.lAN INTERPRETI::R BE NEEDED?

DYES

--~-----

.1 j,,,,

IF YES, PLEAsE IDEtmFYTH5" RS:O~~SifD t\C.C0~1!,m.QA119tl :. :

.

No

-~---

atJ :

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 Rule 1 :38~7{b) .
""" ... ......
~~

ADORNEY SIGNATURE:

Effective

08~19-2013,

. --::_::;, \ .tLC-J_..
I

r"SX- -o..

CN 10517-Engllsh

<'

-page

1 of2

CIVIL CASE INFORMATION STATEMENT

(CIS)
Use for initial pleadings (not motions) under Rule 4:5-1

CASE TYPES (Choose one and enter number of case type In appropriate space on the reverse side.)
Track I

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 UJM CLAlM (coverage Issues only)

511 ACTION ON NEGOTIABLE INSTRUMENT

512 LEMON LAW
601 SUMMARY ACTION
802 OPEN PUBLIC RECORDS ACT (summary acllon)

999

Track II

OTHER {briefly describe nature of aclion)

300 days' discovery

305 CONSTRUCTION
509 EMPLOYMENT (olher than 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
301
602
604
606
607
608
609
616
617
618

CIVIL RIGHTS
CONDEMNATION
ASSAULT AND BATTERY
MEDICAL MALPRACTICE
PRODUCT LIABILITY
PROFESSIONAL MALPRACTICE
TOXIC TORT
DEFAMATION
WHISTLEBLOWER/ CONSCIENTIOUS EMPLOYEE PROTECTION ACT (CEPA) CASES
INVERSE CONDEMNATION
LAW AGAINST DISCRIMINATION (LAD) CASES

Track IV Active Case Management by Individual Judge /450 days' discovery

156
303
508
513
514
620
701

ENVIRONMENTAUENVlRONMENTAL COVERAGE LITIGATION

MT. LAUREL
COMPLEX COMMERCIAL
COMPLEX CONSTRUCTION
INSURANCE FRAUD
FALSE CLAIMS ACT
ACTIONS IN LIEU OF PREROGATIVE WRITS

Multicounty Litigation (Track IV)

266
271
274
276
279
281
282
284
285
286
287

HORMONE REPLACEMENT THERAPY (HRT)

ACCUTANEIISOTRETINOIN
RISPERDAUSEROQUEUZVPREXA
ZOMETNAREDIA
GADOLINIUM
BRISTOL-MYERS SQUIBB ENVIRONMENTAL
FOSAMAX
NUVARING
STRYKER TRIDENT HIP IMPLANTS
LEVAQUIN
YAZ/YASMIN/OCELLA

288
289
290
291
292
293
295
296
297
601
623

PRUDENTIAL TORT LITIGATION

REGLAN
POMPTON LAKES ENVIRONMENTAL LITIGATION
PELVIC MESHIGYNECARE
PELVIC MESH/BARD
DEPUY ASR HIP IMPLANT LITIGATION
ALLODERM REGENERATIVE TISSUE MATRIX
STRYKER REJUVENATE/ABO II MODULAR HIP STEM COMPONENTS
MIRENA CONTRACEPTIVE DEVICE
ASBESTOS
PROPECIA

If you believe tills case requires E\ track other than that provided above, please Indicate the reason on Side 1,
in tho space under "Case Characteristics.

Please check off each applicable category

Effec!ive 08-19-2013, GN 10517-Engl!sh

Putative Class Action

Tille 59

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