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  • Danielle Pierce V New Jersey Department of Children and Families

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    Danielle Pierce v New Jersey Department of Children and Families, Jean Marie Lamb, Mandi Edwards, Michelle Kennedy

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    Danielle Pierce v New Jersey Department of Children and Families

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    Danielle Pierce v New Jersey Department of Children and Families, Jean Marie Lamb, Mandi Edwards, Michelle Kennedy

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    382 Ansichten20 Seiten

    Danielle Pierce V New Jersey Department of Children and Families

    Hochgeladen von

    opracrusades
    Danielle Pierce v New Jersey Department of Children and Families, Jean Marie Lamb, Mandi Edwards, Michelle Kennedy

    Copyright:

    © All Rights Reserved
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    gavis/2014 07:85 pax Booaso24 tracy A. Aenatrong, fsq., 10824721991 Chetstopher M. eddy, Baq., 14015412007 LOMURRO, DAVISON, EASTHAN 4 MUROZ, PLA. Nonnouth Executive Center 100 Willow Brook Road, suite 100 Froshold, Now Jersey 07728 Telephone: 732=462- 1370 Faceimile: 732-780-9723, Attorneys for Plaintitt, Danielle PLeroc} cory SUPERION CT, OGEAN, SUPERIOR COURT OF NEN JERSEY LAM DIVISION OCEAN COUNTY voorar vo: AASbo~ 1Y cCrVEL, agrtow Plaintice, {THE NEN JERSEY DEPARTMENT OF CCUELDREN AND FAMILIES, JEAN MICHELLE KENNEDY, ond SIANE/ JOHN DOES 1°20, Fietitious Persone, Defendants. Plaintiff, Danielle Pierce (hereinafter, “Plaintife”), by way of Complaint against Dofendante, the Ney Jersey Department of Children and Yanilies (hereinafter, “OCP"), yoanmaric Lanb, Mandi Edvarda, Michelle Kennedy, and Yane/vJoha Does 1-10, Fictitious Persons, hereby says: panores 1. —-PLANELEE reaices at 28 Laurel street, Bayville, New Jersey and was an employee of the State of New Jersey for 11 relevant periods of 4 Complaint 2, Vetendant, ‘the Now Jersey Division of children and Fanities ("DCP"), ia a Nev Jersey government agency with offices located in Trenton, New Jersey, Plaintife worked for ber tor relevant periods of this Complaint. 3. Defendant, Joanmarie Lamb, vas a Supervisor in the DCF Ocean South Local Office and was Plaintifere direct supervisor for relevant periods of this complaint. 4. Dofendant, Mandl Edvards wae a cage Work Supervisor in the OCP Ocean South Local Office and was Plaintift’s head supervisor for all relevant periods of this Comptaine. 5. Defendant, michelle Kennedy was the Local office Manager in the OCF Ocean South Local Office and was in charge of the 00 sn South Local Office for relevant periods of thie Complaint. In this position, Defendant Kennedy was fully aware of the workloads for all caseworkers in the Osean South Tocal Office. 6. Bofendante, Jane/fohn Does 1-10, FLetitious anes, ¢rue names and addresses presently unknown was/uere the enployer(e) and/or supervisors of the Plaintiff for all relevant periods to this Complaint, or other agent, ofticer, manager or person othervise Uable to Plaintife under the causes of action act forth herein. gosts/ 014 07:55 Pax ao0s/0 mere iG Plaintis£ began ner omployment with DCP on October 30, 2006 in the position known as Family Service Specialist, 11/Caso Worker. In January of 2008 Plaintite vas Promoted to Family Service Specialist, I1/Child Abuse Investigator. 8 Plaintif® worked in the DCF office known as Ocean South Local, located in Tons River, New Jersey. 8 As a Family Service Specialist, T1, Plaintife’s responsibilities included reviewing cases involving allegations of child abuse, investigating the allegations, senonte conducting visite with the families, pecforming a: of the needs of the children and families, implementing the appropriate services, completing safety risk assessments and completing the required documentation. 10, baring her tenure as 2 Fanily Service Specialist, TX with DoF, Plaintief’s workload continually exceeded the ‘amount alloyed by the Modified Settlement agreement (HSA) which was Leoued by the United States District Court of New Vorsey on uty 18, 2006 in the matter of Charlie and Hadine Hag gt a1 v. Jon 8. Corzine, 20 Governor of the State of New Jersey, and Kevin M. fiyan, a Commissioner of the Nov Jerse; Dopartnont of Children ond Fentiag, civil Action Ne. 99 3678. Anong many other itens, the MSA regulated the caseloads of the caseworkers in ocr, 32, Section & (19) of the MSA atates that by Docenber 2008, 958 of offices shall have average caseloads for the Antake staff at the caseload standard of 12 fanilies or less and @ new referrals per month or 1 12, Plaintiff's caseload greatly exceeded the Limits Got by the MSA. For example, Plaintiff's caseload during the timo jfzone of September 201 through April 2012 wan ae follows: September 2011: 15 cases; November 2021; 15 cases? December 2011: 20 eases vanuary 201: 13) February 201: Mi cases; March 2012: 19 0: ssi and April 2012: 18 cases. Of these cases, several vor considered “high risk” which, required additional monitoring, asseasment and evaluation. 13, Plaintiff made Lt known to both Defendant Edwards and Defendant Lamb that her caseloed exceeded the linits of che MSA, and that she wae overwhelmed end unable to address ‘the needs of each of the cases to which she wae assigned. 14, Defendant Kennedy was avare of the caseload amounts for all caseworkers in the Ocean South Local office. 15, Despite being taken off the intake case rotation in vanuary of 2012 for two (2) wooks, Plaintiff's caseload continusd to exceed the Limit set by the MSA. Despite being eooe/ox4 auare of this fact, Defendants returned Plaintiff to the Antake rotation allowing new cases to be assigned to her. 16. on jeral occasions, Plaintiff had meetings vith both Defendant Lamb and Defendant Kawards to discuss her caseload. Regardless of each of the Defendants being fully avare thit Plaintiff's caseload exceeded the Limit set by NSA, and that Plaintite continually complained about feeling fovarvhelnod and stressed with her tncreasing workload and vas concegned with her ability to competently handle her cases, Derendants continued to ssign additional cases to Plaintiff. 17. On January 12, 2021 Plaintits met with Defendant Lamb to roviow the status of her esi They created s work plan for Plaintift and subseqventiy met on a regular basis to discuss the status of eleintift’s cases, Additionally, Defendant tanb would e-mail Plaintift weekly to identify cases which wore outstanding and List itene vhich needed to be completed. Defendant Edvards was copied on some of these o-naile. 18, As a roault of these meotings, conversations, and e-mails, 1 was evident that Defendant Lamb end Defendant Edwards were fully avaro of the nunber of cases which Plaintift was handling, the actions which had been taken on each one of Plaintirt’s cases, unich actions wore still outstanding, the issues in each of her cast and which cas wore high risk cast 19, Despite the fact that Defendant Lamb, Defendant Bavards and vefendant Kennedy kney that Plaintit{’s caseload exceeded the Limit set by the MSA and that due to the excessive caseload, critical action items were unable to be completed by Plaintiff on some of her ca 15 in an expedited manner, and that sone of thene cases were high risk cases, the Dpfendants did not assist plaintisr with the itews to be completed or provide the means to Plaintiff to ensure that the actions wore performed properly. In their supervisory positions, Defendant Lamb, Defendant Edvards and Defendant. Kennedy had an obligation to assist Plaintier with the | critical items to be completed on her cases to ensure that they weze handled appropriately. 20. From the continual meetings, conversations and = mails between Defendants and Plaintif#, both Defendant tan and Defendant Sdvards were aware of the stresy and anxiety which the excessive caseloed caused Plaintite 21. On February 10, 2012 pefendant Kennedy gent an e- mail to the supervisors in the Ocean South Local office @irecting that they ensure that each ° caseworker 4s in compliance with the MSA. Defendant Kennedy etated in her o~ 2014 07:56 PAK Imai that there would be consequences if there was not major compliance by the end of the month. 22. This directive caused Jeanmarie Lamb to incresse or naragonent, nadgering sid

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