Turner v NJ Dept of Children and Families

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.



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.

2



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.

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

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.

4



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

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 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



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;

7



(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

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

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

9



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

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 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.

11



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

12



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

...... - ~ - - - ·

.....

_ __

. ··-·

.

.

1

j• • 1 ;

16

DO YOU

OR YOUR CLIEtff NEED NlY DJSABJUTYACCOMMODATIONS?

IF YES, PLEAsE

IDEtmFYTH5"

R S : O ~ ~ S i f D t \ C . C 0 ~ 1 , m . Q A 1 1 9 t l : : ·•

DYES l8l No

. f

........

~ . ~ .

.... • , · . •• -··

Wl lAN

INTERPRETI::R BE

NEEDED?

IF

YES,

FOR

WHAT

lANGUAGE?

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

ule 1 3 8 ~ 7 { b )

. --::_::;, \ .tLC§-J_..

DORNEY

SIGNATURE:

I

r SX- -o..

<'

Effective 0 8 ~ 1 9 - 2 0 1 3

CN

10517-Engllsh

page

1 of2



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

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Turner v NJ Dept of Children and Families

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