Ocean County Jail Response - Haberbush and Dickinson

Case 3:18-cv-00256-BRM-DEA Document 13 Filed 06/11/18 Page 1 of 31 PageID: 174
GILMORE & MONAHAN, P.A.

Ten Allen Street
P.O. Box 1540
Toms River, NJ 08754
(732) 240-6000
Attorneys for Defendants, John Haberbush and Joshua Dickinson
UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY
SARAH PRIOLI, an individual; :

ELIZABETH CLARKE, an individual; Civil Action No. 18-256 (BRM-DEA)
NICOLE HORAN, an individual; :
THERESA WALLACE, an individual;
JODY NEILSON, an individual; : ANSWER TO AMENDED COMPLAINT,
SEPARATE DEFENSES AND
Plaintiffs, : COUNTERCLAIM
v. :
COUNY OF OCEAN, SANDRA MUELLER, :

JOSEPH VALENTI, JOHN HABERBUSH
AND JOSHUA DICKINSON, :
Defendants. :
Defendants, John Haberbush and Joshua Dickinson, having the business
address of 114 Hooper Avenue, P.O. Box 2191, Toms River, NJ 08754-2191, by way of Answer to
the Complaint, say:
I. NATURE OF ACTION
1. Denied.
II. JURISDICTION AND VENUE

GILMORE & MONAHAN
A Professional Corporation
COUNSELLORS AT LAW
Allen Street Professional Center
Ten Allen Street
P.O. Box 1540
Toms River, New Jersey 08754
2. Denied.
3. Denied.
III. EXHAUSTION OF ADMINSTRATIVE REMEDIES
4. This paragraph calls for legal conclusions, no response is required and Defendants
Leave Plaintiffs to their proofs.
5. This paragraph calls for legal conclusions, no response is required and Defendants
Leave Plaintiffs to their proofs.
III. PARTIES
A. The Plaintiff
6. Admit that Plaintiff has been employed by the County of Ocean since on or about
May of 2011 and Defendants leave Plaintiff to her proofs for any remaining allegations.
September of 1994 and Defendants leave Plaintiff to her proofs for any remaining allegations.
September of 2007 and Defendants leave Plaintiff to her proofs for any remaining allegations.
October of 2000 and Defendants leave Plaintiff to her proofs for any remaining allegations.
August of 2014 and Defendants leave Plaintiff to her proofs for any remaining allegations.
B. The Defendants
11. Admitted.
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
12. Admit only that Sandra Mueller is currently employed as the Warden of the Ocean
P.O. Box 1540
County Department of Corrections.
2
13. Admit only that Joseph Valenti is currently employed as the Deputy Warden of the
Ocean County Department of Corrections.
14. Admit only that John Haberbush is currently employed as a Captain of the Ocean
County Department of Corrections.
15. Admit only that Joshua Dickinson is currently employed as a Lieutenant of the
Ocean County Department of Corrections.
IV. GENERAL ALLEGATIONS
A. Introduction
16. Defendants admit only to the language currently contained on the Ocean County
Department of Corrections’ website and Defendant leave Plaintiffs to their proofs for any remaining
allegations.
17. Defendants admit that there are both male and female inmates and employees and
Defendants leave Plaintiffs to their proof for any additional allegations. To the extent that this
paragraph contains any factual allegations directed to the answering Defendant, denied.
18. Defendants admit that the inmates are primarily divided according to security
threat and Defendants leave Plaintiffs to their proof for any additional allegations. To the extent that
this paragraph contains any factual allegations directed to the answering Defendant, denied.
19. Defendants admit that there are administrative and operational units within the
Department and that there are Officers, Sergeants, Lieutenants and Captains and Defendants leave
Plaintiffs to their proof for any additional allegations.
20. Defendants neither admit or deny the statements as set forth and Defendants leave
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
Plaintiffs to their proofs.
P.O. Box 1540
3
B. Discrimination, Disparate Treatment and the Hostile Work Environment
24. Defendants admit that Plaintiffs are current employees with the Ocean County
Department of Corrections and Defendants leave Plaintiffs to their proofs for any remaining
allegations.
25. Denied.
26. Denied.
27. Denied.
28. Denied.
29. Denied.
30. Denied.
31. Denied.
32. Denied.
33. Denied.
34. Denied.
35. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
C. Claims filed with the EEOC
P.O. Box 1540
4
36. To the extent that this paragraph contains any factual allegations directed to the
answering Defendants, denied, and Defendants leave Plaintiffs to their proofs for any remaining
allegations.
37. Denied.
V. PLAINTIFF’S INDIVIDUAL ALLEGATIONS
A. Sarah Prioli
38. Defendants admit that Plaintiff began working for the County of Ocean in or about
May of 2011.
39. Denied.
40. Denied.
41. Denied.
42. Denied.
43. Denied.
44. Denied.
45. Denied.
46. Denied.
47. Denied.
48. Denied.
49. Denied.
50. Denied.
51. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
52. Denied.
P.O. Box 1540
53. Denied.
5
B. Elizabeth Clarke
54. Defendants admit that Plaintiff began her employment with the Ocean County
Department of Corrections in or about September of 1994.
55. Denied.
56. Denied.
57. Denied.
58. Denied.
59. Denied.
60. Denied.
61. Denied.
62. Denied.
63. Denied.
64. Denied.
65. Denied.
66. Denied.
67. Denied.
68. Denied.
69. Denied.
70. Denied.
71. Denied.
72. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
73. Denied.
P.O. Box 1540
74. Denied.
6
75. Denied.
C. Nicole Horan
76. Defendants admit that Plaintiff began her employment with the Ocean County
Department of Corrections in or about September of 2007.
77. Denied.
78. Denied.
79. Denied.
80. Denied.
81. Denied.
82. Denied.
83. Denied.
84. Denied.
85. Denied.
86. Denied.
87. Denied.
88. Denied.
89. Denied.
90. Denied.
91. Denied.
92. Denied.
D. Jody Neilson
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
93. Denied.
P.O. Box 1540
94. Denied.
7
95. Denied.
96. Denied.
97. Denied.
E. Theresa Wallace
98. Denied.
99. Denied.
100. Denied.
101. Denied.
102. Denied.
103. Denied.
104. Denied.
105. Denied.
106. Denied.
107. Denied.
108. Denied.
109. Denied.
110. Denied.
111. Denied.
112. Denied.
113. Denied.
114. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
115. Denied.
P.O. Box 1540
116. Denied.
8
CAUSES OF ACTION
COUNT I
Intentional Discrimination in Violation of Title VII

(by Plaintiffs Prioli, Clarke and Horan against Defendant Ocean County)
117. Defendants repeat their answers to the previous allegations as if the same were
more fully set forth at length herein.
118. Denied.
119. Denied.
120. Denied.
WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,
demand judgment dismissing the Complaint with prejudice, for reasonable attorney's fees, costs of
suit, and for such other relief as the Court deems equitable and just.
COUNT III
Intentional Discrimination in Violation of Section 1981

(by All Plaintiffs against Defendant Ocean)
122. Denied.
123. Denied.
124. Denied.
125. Denied.
126. No allegations are set forth in this paragraph.

GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
P.O. Box 1540
9
COUNT III
Intentional Discrimination in Violation of the New Jersey Law Against Discrimination

(N.J.Stat. §10:5-1, et seq.)
128. Denied.
129. Denied.
130. Denied.
131. Denied.
COUNT IV
Hostile Work Environment in Violation of Section 1981

133. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
134. Denied.
Ten Allen Street
P.O. Box 1540
Toms River, New Jersey 08754 135. Denied.
10
136. Denied.
137. Denied.
138. Denied.
139. Denied.
140. Denied.
141. Denied.
COUNT V
Hostile Work Environment in Violation of Title VII

(by Plaintiffs Prioli, Clarke and Horan against Defendant Ocean)
143. Denied.
144. Denied.
145. Denied.
146. Denied.
147. Denied.
148. Denied.
149. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
150. Denied.
Ten Allen Street
P.O. Box 1540
11
COUNT VI
Hostile Work Environment in Violation of New Jersey Law Against Discrimination

153. Denied.
154. Denied.
155. Denied.
156. Denied.
157. Denied.
158. Denied.
159. Denied.
160. Denied.
161. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
COUNT VII
Ten Allen Street
P.O. Box 1540
Toms River, New Jersey 08754 Retaliation in Violation of Section 1981
12
163. Denied.
164. Denied.
165. Denied.
166. Denied.
167. Denied.
168. Denied.
169. Denied.
170. Denied.
171. Denied.
COUNT VIII
Retaliation in Violation of Title VII

(by Plaintiffs Prioli, Clarke and Horan against Defendant Ocean)
173. Denied.
174. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
175. Denied.
P.O. Box 1540
176. Denied.
13
177. Denied.
178. Denied.
179. Denied.
180. Denied.
181. Denied.
COUNT IX
Retaliation in Violation of New Jersey Law Against Discrimination

(N.J.Stat. §10:5-1, et seq.)
183. Denied.
184. Denied.
185. Denied.
186. Denied.
187. Denied.
188. Denied.
189. Denied.
190. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
191. Denied.
P.O. Box 1540
14
COUNT X
Violation of the New Jersey Conscientious Employees Protection Act

193. Denied.
194. Denied.
195. Denied.
196. Denied.
197. Denied.
198. Denied.
199. Denied.
200. Denied.
201. Denied.
COUNT XI
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
(by All Plaintiffs against Defendant Mueller)
P.O. Box 1540
15
203. Denied.
204. Denied.
205. Denied.
206. Denied.
207. Denied.
COUNT XII

(by Plaintiffs Prioli, Clarke, Horan against Defendant Mueller)
209. Denied.
210. Denied.
211. Denied.
212. Denied.
213. Denied.

GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
P.O. Box 1540
Toms River, New Jersey 08754 suit, and for such other relief as the Court deems equitable and just.
16
COUNT XIII
Defendant Mueller, Aiding and Abetting Employment Discrimination at Ocean in Violation of

N.J.S.A. §10:5-12e
(by All Plaintiffs)
215. Denied.
216. Denied.
217. Denied.
218. Denied.
219. Denied.
COUNT XIV
Retaliation in Violation of Section 1981

(by All Plaintiffs against Defendant Mueller)
221. Denied.
222. Denied.
223. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
224. Denied.
Ten Allen Street
P.O. Box 1540
17
226. Denied.
227. Denied.
COUNT XV
Retaliation in Violation of Title Vii

(by Plaintiffs Prioli, Clarke and Horan against Defendant Mueller)
229. Denied.
230. Denied.
231. Denied.
232. Denied.
233. Denied.
234. Denied.
235. Denied.
COUNT XVI
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
(by All Plaintiffs against Defendant Valenti)
P.O. Box 1540
18
237. Denied.
238. Denied.
239. Denied.
240. Denied.
241. Denied.
COUNT XVII

(by All Plaintiffs Prioli, Clarke, Horan against Defendant Valenti)
243. Denied.
244. Denied.
245. Denied.
246. Denied.
247. Denied.

GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
P.O. Box 1540
Toms River, New Jersey 08754 suit, and for such other relief as the Court deems equitable and just.
19
COUNT XVIII
Defendant Valenti Aiding and Abetting Employment Discrimination at Ocean in Violation of

N.J.S.A. §10:5-12e
(by All Plaintiffs)
249. Denied.
250. Denied.
251. Denied.
253. Denied.
COUNT XIX

(by Plaintiffs against defendant Valenti)
255. Denied.
256. Denied.
257. Denied.
258. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
259. Denied.
Ten Allen Street
P.O. Box 1540
20
COUNT XX

(by Plaintiffs Prioli, Clarke and Horan against Defendant Valenti)
262. Denied.
263. Denied.
264. Denied.
265. Denied.
266. Denied.
267. Denied.
268. Denied.
COUNT XXI

(by Plaintiffs Clarke, Horan, Prioli, Wallace against Defendant Haberbush)
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
P.O. Box 1540
270. Denied.
21
271. Denied.
272. Denied.
273. Denied.
274. Denied.
COUNT XXII

(by Plaintiffs Prioli, Clarke and Horan against Defendant Haberbush)
276. Denied.
277. Denied.
278. Denied.
279. Denied.
280. Denied.
COUNT XXIII
GILMORE & MONAHAN
COUNSELLORS AT LAW
Defendant Haberbush Aiding and Abetting Employment Discrimination at Ocean in Violation
Ten Allen Street
of N.J.S.A. §10:5-12e
P.O. Box 1540
Toms River, New Jersey 08754 (by All Plaintiffs)
22
282. Denied.
283. Denied.
284. Denied.
285. Denied.
286. Denied.
COUNT XXIV

(by all Plaintiffs against Defendant Haberbush)
288. Denied.
289. Denied.
290. Denied.
291. Denied.
292. Denied.
293. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
P.O. Box 1540
23
COUNT XXV

(by Plaintiffs Prioli, Clarke and Horan against Defendant Haberbush)
295. Denied.
296. Denied.
297. Denied.
298. Denied.
299. Denied.
300. Denied.
COUNT XXVI

(by Plaintiffs Prioli, Clarke and Horan against Defendant Dickinson)

GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
302. Denied.
P.O. Box 1540
303. Denied.
24
304. Denied.
305. Denied.
306. Denied.
COUNT XXVII

(by Plaintiffs Prioli, Clarke and Horan against Defendant Dickinson)
308. Denied.
309. Denied.
310. Denied.
311. Denied.
312. Denied.
COUNT XXVIII
Defendant Dickinson Aiding and Abetting Employment Discrimination at Ocean in Violation

of N.J.S.A. §10:5-12e
GILMORE & MONAHAN
COUNSELLORS AT LAW
(by Plaintiffs Prioli, Clarke and Horan Against Defendant Dickinson)
Ten Allen Street
P.O. Box 1540
25
314. Denied.
315. Denied.
316. Denied.
317. Denied.
318. Denied.
COUNT XXIX

(by Plaintiffs Prioli, Clarke and Horan against Dickinson)
320. Denied.
321. Denied.
322. Denied.
323. Denied.
324. Denied.
325. Denied.
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
P.O. Box 1540
26
COUNT XXX

(by Plaintiffs Prioli, Clarke and Horan against Dickinson)
327. Denied.
328. Denied.
329. Denied.
330. Denied.
331. Denied.
332. Denied.
SEPARATE DEFENSES
1. The Complaint fails to state a cause of action upon which relief can be granted.
2. Defendants were not negligent.
3. Injuries complained of are the result of plaintiff’s own negligence.

GILMORE & MONAHAN
COUNSELLORS AT LAW
4. The accident and injuries alleged were caused or contributed to by the negligence
Ten Allen Street
P.O. Box 1540
Toms River, New Jersey 08754 of others over whom these Defendants have no control and for whom they had no legal liability.
27
5. While denying any negligence for the accident and injuries alleged, should the
negligence of Plaintiffs be found to be not greater than that of Defendants, these Defendants
demand damages be diminished by this percentage of negligence attributable to Plaintiffs, pursuant
to the Comparative Negligence Act, N.J.S.A. 2A:15-5.1 et seq.
6. This suit is barred by the Statute of Limitations.
7. The applicability of the provisions of N.J.S.A. 59:2-1 and N.J.S.A. 59:2-2, as to the
immunities available to the public entity and/or public employee are asserted.
8. The applicability of the provisions of N.J.S.A. 59:2-3 and N.J.S.A. 59:3-2, as to the
absence of liability from the exercise of judgment or discretion are asserted.
9. The applicability of the provisions of N.J.S.A. 59:2-4, N.J.S.A. 59:3-3 and N.J.S.A.
59:3-4, as to the non-liability for any injury caused by adopting or failing to adopt a law or by
failing to enforce a law are asserted.
10. The applicability of the provisions of N.J.S.A. 59:3-5 as to the non-liability of a
public employee for an injury caused by its adoption or failure to adopt any law or by its failure to
enforce any law are asserted.
11. The applicability of the provisions of N.J.S.A. 59:5-4 as to the failure to provide
police protection service are asserted.
12. The applicability of the provisions of N.J.S.A. 59:8-3 through N.J.S.A. 59:8-7
regarding failure to provide adequate notice of claim are asserted.
regarding failure to timely file notice of claim are asserted.

GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
P.O. Box 1540
concerning conditions of suit and judgment are asserted.
28
15. The accident and injuries alleged were caused or contributed to by the negligence
of others over whom this defendant had no control and for whom he has no legal liability.
16. At all times mentioned in the Complaint any and all actions or omissions of the
defendant relating in any way to plaintiff’s alleged damages involved decisions of the defendants
within an area of non-actionable governmental discretion. By virtue of the said discretion,
defendants are not liable to any party herein.
17. At all times defendants acted in good faith and accordingly are immune from any
liability to the plaintiffs.
18. These defendants did not act in any conspiracy against the plaintiffs.
19. Plaintiffs’ civil rights were not violated.
20. These defendants acted in good faith and based on reasonable cause.
21. At all times pertinent to the allegations contained within the plaintiffss’ complaint,
these defendants acted within the boundaries of their lawful authority.
22. These defendants, at no time pertinent to the allegations contained within
plaintiffs’ complaint, acted intentionally, knowingly or maliciously in such a manner so as to cause
the injuries alleged by the plaintiffs.
23. At all times pertinent to the allegations contained within plaintiffs’ complaint,
these defendants acted reasonably and properly in the execution of their duties.
25. These defendants are entitled to qualified immunity.
26. These defendants are entitled to absolute immunity.
28. These defendants were acting in accordance with clearly established standards and
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
accordingly are not liable to the plaintiffs.
P.O. Box 1540
29
29. The municipal defendants and all defendants acting in their official capacity are
immune from punitive damages under the Civil Rights Act, 42 U.S.C. § 1983 and the New Jersey
Tort Claims Act, N.J.S.A. 59:1-1 et. seq.
30. The cause of action alleged by the plaintiff is not cognizable.
31. Plaintiffs’ complaint is barred by the Doctrine of Collateral Estoppel.
32. The complaint is insufficient and violates the Local Civil Rules governing the
District of New Jersey.
33. Defendants did not intentionally discriminate or retaliate in violation of Section
1981 or Title VII.
34. Defendants did not aid or abet in employment discrimination in violation of
N.J.S.A. §10:5-12e.
35. Plaintiffs did not suffer adverse employment consequence.
36. Plaintiffs failed to exhaust their administrative remedies.
37. Plaintiffs are not entitled to compensatory or punitive damages.
38. Defendants did not create a hostile work environment.
39. Plaintiffs did not suffer disparate treatment.
40. Defendants hereby reserve the right to interpose such other defenses and objections
as continuing discovery may disclose.
COUNTERCLAIM FOR ATTORNEYS' FEES
1. The allegations contained in the Plaintiff's complaint and any amended complaint
are frivolous, groundless, and without merit as to the answering Defendants, JOHN HABERBUSH
GILMORE & MONAHAN
COUNSELLORS AT LAW
Ten Allen Street
AND JOSHUA DICKINSON.
P.O. Box 1540
30
2. 42 U.S.C. § 1988 provides for the allowance of reasonable attorneys' fees to the
prevailing party in an action or proceeding arising out of an alleged violation of § 1981, 1982, 1983,
1985, and 1986 of Title 42 of the United States Code.
LOCAL CIVIL RULE 11.2 CERTIFICATION
The undersigned counsel hereby certifies that the within matter in controversy is not the
subject of any other action pending in any court or of a pending arbitration or administrative
proceeding and that, to the best of counsel’s knowledge, there is no other party who should be
joined in this action.
DEMAND FOR JURY TRIAL
Demand is hereby made for a trial by jury as to all issues.
DESIGNATION OF TRIAL COUNSEL
Pursuant to the Rules of Court, Jared J. Monaco, Esq., has been designated as trial
counsel in connection with this matter.
GILMORE & MONAHAN, P.A
Attorneys for Defendants, John Haberbush and

Joshua Dickinson
By /s/ Jared J. Monaco

JARED J. MONACO
Date: June 11, 2018 For the Firm
GILMORE & MONAHAN
COUNSELLORS AT LAW
File #3500-175
Ten Allen Street
P.O. Box 1540
31

Ocean County Jail Response - Haberbush and Dickinson

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Case 3:18-cv-00256-BRM-DEA Document 13 Filed 06/11/18 Page 1 of 31 PageID: 174

GILMORE & MONAHAN, P.A.

UNITED STATES DISTRICT COURT

SARAH PRIOLI, an individual; :

COUNY OF OCEAN, SANDRA MUELLER, :

Defendants, John Haberbush and Joshua Dickinson, having the business

the Complaint, say:

II. JURISDICTION AND VENUE

III. EXHAUSTION OF ADMINSTRATIVE REMEDIES

Leave Plaintiffs to their proofs.

Leave Plaintiffs to their proofs.

County Department of Corrections.

Ocean County Department of Corrections.

County Department of Corrections.

Ocean County Department of Corrections.

IV. GENERAL ALLEGATIONS

Plaintiffs to their proof for any additional allegations.

Plaintiffs to their proofs.

Plaintiffs to their proofs.

Plaintiffs to their proofs.

B. Discrimination, Disparate Treatment and the Hostile Work Environment

V. PLAINTIFF’S INDIVIDUAL ALLEGATIONS

Department of Corrections in or about September of 1994.

Department of Corrections in or about September of 2007.

Intentional Discrimination in Violation of Title VII

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Intentional Discrimination in Violation of Section 1981

more fully set forth at length herein.

126. No allegations are set forth in this paragraph.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Intentional Discrimination in Violation of the New Jersey Law Against Discrimination

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Hostile Work Environment in Violation of Section 1981

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Hostile Work Environment in Violation of Title VII

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Hostile Work Environment in Violation of New Jersey Law Against Discrimination

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Retaliation in Violation of Title VII

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Retaliation in Violation of New Jersey Law Against Discrimination

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Violation of the New Jersey Conscientious Employees Protection Act

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Intentional Discrimination in Violation of Title VII

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Defendant Mueller, Aiding and Abetting Employment Discrimination at Ocean in Violation of

more fully set forth at length herein.

WHEREFORE, Defendants, JOHN HABERBUSH AND JOSHUA DICKINSON,

Retaliation in Violation of Section 1981

more fully set forth at length herein.