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Bonjean Law Group, PLLC
1000 Dean St., Ste. 345

Brooklyn, New York 11238
Tel: (718) 875-1850
Fax: (718) 230-0582
jennifer@bonjeanlaw.com
Attorney for Plaintiff

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
CAMDEN VICINAGE

CHRISTINE MEALE,

Plaintiff,
COMPLAINT
AND JURY TRIAL DEMAND
v.

CITY OF EGG HARBOR CITY;
POLICE OFFICER STEVEN HADLEY;
POLICE OFFICER CHRISTOPHER
HOFFMAN; UNKNOWN EGG HARBOR
POLICE OFFICERS.

Defendants.

NOW COMES Plaintiff, CHRISTINE MEALE, by and through her attorney,
JENNIFER BONJEAN of the BONJEAN LAW GROUP, PLLC, and for cause of action
against the defendants, both jointly and severally, respectfully states as follows:
INTRODUCTION
1. On January 15, 2013, Plaintiff, Christine Meale was forced into a five-month
nightmare where she was the victim of repeated sexual assault and emotional torment at the
hands of disgraced Egg Harbor City police officer Steven Hadley.
2. Following her unlawful arrest for possession of a controlled substance, defendant
Hadley promised Plaintiff that if she cooperated with him, he would make sure that the charges
Case 1:14-cv-05860-RMB-JS Document 1 Filed 09/22/14 Page 1 of 20 PageID: 1
against her were dropped. Plaintiff, a wife and mother of a young child, agreed to act as an
informant for defendant Hadley with the understanding that the charges against her would be
dropped.
3. Defendant Hadley misled Plaintiff into believing she was a confidential
informant when he directed Plaintiff to make drug purchases that he retained for his personal
use.
4. Moreover, defendant Hadley repeatedly coerced Plaintiff to engage in sexual acts
with him, demanding that she meet him at the Egg Harbor Police station and other locations for
the purpose of sexually abusing her. Terrified and vulnerable, Plaintiff acquiesced to Hadleys
demands, fearing that she would go to prison if she refused.
5. Defendant Hadleys abuse of Plaintiff continued for nearly five months.
Defendant Hadley was eventually criminally charged with official misconduct related to his
conduct against Plaintiff and at least three other women dating back to 2010.
6. Other Egg Harbor City police officers, Defendant Hadleys supervisors and even
the Chief of Police were aware of defendant Hadleys misconduct and did nothing to protect
Plaintiff and the other victims of his abuse.
PARTIES
7. Plaintiff is an adult resident citizen of Egg Harbor City, Atlantic County, New
Jersey.
8. Defendant Egg Harbor City, New Jersey, is a municipality chartered by the State
of New Jersey and as such is a political subdivision of the State of New Jersey and among its
other functions operates and maintains a law enforcement agency known as the Egg Harbor City
Police Department. Egg Harbor City is under a duty to run its policing activities in a lawful
manner so as to preserve the rights, privileges, and immunities guaranteed and secured to them
by the constitutions and laws of the United States and the State of New Jersey.
9. On information and belief, defendant Egg Harbor City Police Officer Steven
Hadley is an adult resident citizen of the city of Port Republic, Atlantic County, New Jersey. At
all times material hereto, defendant Hadley was a member of the Egg Harbor City Police
Department and was acting by virtue of his position as a law enforcement officer of the Egg
Harbor City Police Department and under the color of state law. Defendant Hadley is sued
individually and in his official capacity as a member of the Egg Harbor City Police Department.
10. On information and belief, defendant Egg Harbor City Police Officer Christopher
Hoffman is an adult resident citizen of Atlantic County, New Jersey. At all times material hereto,
defendant Hoffman was a member of the Egg Harbor City Police Department and was acting by
virtue of his position as a law enforcement officer of the Egg Harbor City Police Department and
under the color of state law. Defendant Hoffman is sued individually and in his official capacity
as a member of the Egg Harbor City Police Department.
11. On information and belief, defendants unknown Egg Harbor City Police Officers
are adult resident citizens of Atlantic County, New Jersey. At all times material hereto,
defendants unknown Egg Harbor Police Officers were members of the Egg Harbor Police
Department and were acting by virtue of their position as a law enforcement officers of the Egg
Harbor Police Department and under the color of state law. Defendants unknown Egg Harbor
City Police Officer are sued individually and in their official capacities as members of the Egg
Harbor City Police Department.
JURISDICTION AND VENUE
12. Each and all acts of defendants were performed under the color and pretense of
the Constitutions, statutes and ordinances, regulations, customs, and usages of the United States
of America, the State of New Jersey, the County of Atlantic, and the City of Egg Harbor, and
under the authority of their office as law enforcement officers for Egg Harbor, New Jersey.
13. The incidents which give rise to this cause of action occurred within this
jurisdiction and within two years of the filing of this Complaint.
14. Venue is proper in this venue pursuant to 28 U.S.C. 1391, as all the defendants
are residents of this district and/or all the acts or omissions which give rise to this cause of action
occurred within this district.
15. Jurisdiction is proper pursuant to federal question jurisdiction, 28 U.S.C. 1331,
28 U.S.C. 1343(a)(3)(4) and 42 U.S.C. 1983. Plaintiffs further invoke the pendent and
supplemental jurisdiction of this Court to hear and decide claims arising under state law pursuant
to 28 U.S.C. 1367
FACTUAL ALLEGATIONS
Plaintiff hereby incorporates, in their entirety, each and every paragraph contained in this
complaint and by reference makes said paragraphs a part hereof as if fully set forth herein:
16. On the evening of January 15, 2013, Plaintiff, a hair stylist, drove to the home of a
friend/customer to do her hair.
17. At the conclusion of the appointment, Plaintiff prepared to leave the residence and
was asked by a male friend of her customer if she would give him a ride to a near-by gas station
to buy cigarettes.
18. Plaintiff agreed and left the house accompanied by the male passenger. After
driving less than a mile, Plaintiff was pulled over on the White Horse Pike by an Egg Harbor
City marked police car.
19. Egg Harbor Police officer Defendant Hoffman parked behind Plaintiffs van,
exited his car, and walked over to the passenger side of Plaintiffs van. On information and
belief, defendant Hoffman knew the male passenger in Plaintiffs car because he immediately
stated to the male passenger, [Y]ou have warrants, and ordered him out of the van.
20. Defendant Hoffman instructed Plaintiff to place her hands on the steering wheel
while he handcuffed the male passenger and directed him to sit on the curb of the street.
21. Defendant Hoffman walked over to the drivers side of the van where Plaintiff
provided defendant with her drivers license, vehicle registration and insurance card, all of which
were in good order. Defendant Hoffman then instructed Plaintiff to exit the vehicle and she
complied.
22. Upon exiting the vehicle, Detective Hoffman placed Plaintiff into handcuffs.
Defendant Hoffman asked Plaintiff if she had any drugs in her possession and began searching
her person. Plaintiff did not consent to the search.
23. Defendant Hoffman proceeded to fondle Plaintiff. Defendant Hoffman patted
down Plaintiffs entire body on the outside of her clothes; unbuttoned her jeans and pulled them
away to expose her vaginal area which was covered by her underwear. He then reached into her
pants with both hands in a swiping motion touching her buttocks and vaginal area over her
underwear. He dug into all of her jean pockets, including an inside pocket, front pockets, and
back pockets; loosened her shirt feeling under her shirt; and reaching into and under her bra
moving his hands across her bare breasts.
24. Shortly after defendant Hoffman conducted the intrusive and unlawful search of
Plaintiff, Defendant Hadley arrived on the scene, driving a white truck. Defendant Hoffman left
Plaintiff standing humiliated on the side of the public road with her bra exposed and her pants
undone as he conferred with other officers who had arrived on the scene, including Hadley.
25. Defendant Hadley then searched Plaintiffs van and purse without her consent and
discovered a small bag of marijuana. Defendant Hadley asked Plaintiff in sum and substance,
[I]s this all you got?
26. Defendant Hadley and Defendant Hoffman conferred and appeared to gesture
toward an adjacent parking lot affiliated with a bowling alley. Plaintiffs car was relocated to the
bowling alley parking lot and Plaintiff was placed in the back of defendant Hoffmanns police
car.
27. Defendant Hoffman transported Plaintiff to the Egg Harbor City Police
Department in Egg Harbor City. While driving there, Defendant Hoffman informed Plaintiff that
his supervisor wanted to talk to her. Defendant Hoffman told her that if she worked with them,
she could avoid being charged.
28. Frightened and vulnerable, Plaintiff confessed to both Hoffmann and Hadley that
she had a family and a young daughter; that she was a recovering drug addict but had recently
relapsed and did not want to go to jail. Defendant Hadley assured Plaintiff that if she
cooperated, she wouldnt be in any trouble. Plaintiff then admitted that she had two small bags
of heroin in the padding of her bra.
29. When Plaintiff arrived at the police station, she was taken into a room where
several other uniformed officers were located. She was placed on a bench with one hand cuffed
to the bench and the other hand free.
30. One officer began to process Plaintiff and started to take her fingerprints. During
the booking process, the officer taking Plaintiffs fingerprints was interrupted by Defendant
Hadley who whispered in his ear.
31. To the best of her recollection, Plaintiff soon found herself alone in a room with
Defendant Hadley and Defendant Hoffman, who was working on a computer.
32. Defendant casually approached Plaintiff while she was seated, leaned back on a
piece of office furniture and placed his leg up and said quietly, you know, this will all go away
if you just give me a little. On information and belief, Detective Hoffman heard Hadleys
statements to Plaintiff.
33. Defendant Hadley then stated, bring her to my office, and left the area. Shortly
thereafter, Plaintiffs handcuffs were removed and she was escorted to Defendant Hadleys
office.
34. Once inside defendant Hadleys office, Plaintiff began to cry and plead with
Hadley to not charge her. Plaintiff offered to help Hadley by being an informant. Defendant
Hadley repeatedly told her to calm down and calm down babe, we can work something out.
35. Defendant Hadley then instructed Plaintiff to lift up her shirt so he could see her
tits. Intimidated and terrified, Plaintiff complied by lifting up her shirt just a little and at the
same time asked, [C]ant I just be an informant?
36. Defendant Hadley replied in sum and substance let me see your tits, pull it up, no
one is in here. Plaintiff complied. Hadley told Plaintiff that she could be an informant.
37. Defendant Hadley then led Plaintiff out of his office into another area of the
police station while telling her, Im going to let you go tonight.
38. Plaintiff then prepared to leave and was able to arrange a ride home from her
brother-in-law. Before leaving, however, a different officer gave her two tickets and a complaint
and summons for court.
39. In and around week later, Plaintiff contacted Defendant Hadley on a cell phone
number that he had provided to her and asked him whether she could still be an informant as
he promised in exchange for the charges against her being reduced or dropped.
40. Over the next several days, Defendant Hadley began texting Plaintiff repeatedly.
He often used the term babe and assured her that if she cooperated with him, everything
would be taken care of.
41. At that time, Plaintiff believed that defendant Hadley planned to use her as a drug
informant in exchange for getting her charges dropped. At Hadleys direction, Plaintiff met him
at the police station not long after her arrest.
42. Between January, 2013 and May, 2013, defendant Hadley instructed Plaintiff to
come to the police station on numerous occasions. Hadley escorted Plaintiff through the rear
entrance of the police station. On most if not all occasions, other police officers were present in
the area. On information and belief, these other officers, including supervisors, saw Plaintiff in
the Egg Harbor City police station meeting with Hadley in private.
43. During these meetings with defendant Hadley, Plaintiff repeatedly asked him to
formalize her role as a confidential information and clarify how she could avoid the charges
that were pending against her. Defendant Hadley told her repeatedly that everything would be
taken care of. At Plaintiffs insistence, Hadley eventually provided Plaintiff with an
agreement to sign which Hadley promised would formalize her position as an informant.
44. Also during these meetings at the police station, and other locations including the
Egg Harbor Boat Yard, Defendant Hadley insisted that Plaintiff perform oral sex on him and on
at least one occasion demanded that Plaintiff engage in vaginal intercourse with him.
45. Over the several month period from January, 2013 to May of 2013 defendant
Hadley frequently texted Plaintiff with sexually explicit language and demanded that she respond
in kind and send photos of her bare breasts and exposed genitalia.
46. Plaintiff reluctantly complied with defendant Hadleys requests out of fear that if
she didnt, she would be indicted, convicted and sent to prison. Plaintiff lived in fear of going to
jail all while trying to keep the sexual abuse a secret from her husband. On numerous occasions,
Plaintiff begged Hadley to just let her be an informant and not engage in sexual activity with
him.
47. Between January, 2013 and May of 2013 defendant Hadley also demanded that
Plaintiff use her own funds to purchase narcotics, including crystal methamphetamine (crystal
meth) On each of those occasions defendant Hadley would follow her to the location of
purchase in his personal vehicle.
48. Each time Plaintiff purchased crystal meth at the direction of defendant Hadley,
he tested the narcotic in his office with what appeared to be an official testing kit. On each
occasion he would comment whether the crystal meth was good or bad. Plaintiff never saw
defendant Hadley fill out any paperwork regarding the purchase of the narcotics, nor did she ever
see him inventory the narcotics. Plaintiff was never asked to sign any type of CI voucher or any
other documentation nor was she reimbursed for the money she used to purchase the narcotics.
On information and belief, defendant Hadley was actually using the narcotics himself.
49. Finally in Spring of 2013, Defendant Hadley demanded that Plaintiff meet him
during the day outside a building that is used for the 4H fair. Plaintiff complied.
50. When Plaintiff arrived at the desolate area, she parked and entered defendant
Hadleys white truck as he instructed. Hadley was giggling and acting strangely.
51. Upon entering the car Defendant Hadley exposed his penis and demanded that
Plaintiff suck my dick. Plaintiff began to cry.
52. Plaintiff pleaded with Hadley to just let her be a confidential informant and
begged him to provide her with copies of her confidential informant agreement and any other
documentation to show that she had been acting as a confidential informant. Defendant Hadley
reiterated that he had her covered and that she was not going to jail but refused to provide
her with any paperwork.
53. Defendant Hadley allowed Plaintiff to exit the car without demanding any further
sexual acts.
54. Hadley continued to communicate with Plaintiff over the next few weeks by text.
Emotionally drained, sleep-deprived, and on the verge of a nervous breakdown, Plaintiff refused
to meet Hadley face-to-face. Plaintiff eventually pled guilty to possession of CDS.
55. Several months later, Plaintiff spoke with a prosecutor from the Atlantic County
Prosecutors office who was investigating official misconduct committed by defendant Hadley.
56. On September 24, 2013, defendant Hadley was criminally charged with official
misconduct related to his interactions with Plaintiff. The complaint alleged that within the
jurisdiction of this court, and as a public servant, did commit and act related to his office but
constituting an unauthorized exercise of his official functions with the purpose of obtaining a
benefit for himself, to wit did engage in sexual contact with C.M. during the course of his official
duties of various dates between January 2013-May 2013.
57. Defendant Hadley was charged with committing the same conduct against three
other women, dating back to January 2010.
58. On information and belief, prior to defendant Hadleys abuse of Plaintiff, several
women complained to either Egg Harbor police department personnel, the Atlantic County
Prosecutors office, or other individuals in a supervisory capacity about defendant Hadleys
misconduct and abuse of power, including his pattern of demanding sexual favors from women
in vulnerable situations.
59. Defendant Hadleys repeated acts of sexual abuse of women and other forms of
official misconduct were a well-known fact in the Egg Harbor City police department and even
outside the police department. Indeed, the Chief of Police of the Egg Harbor Police Department
was fully aware of Hadleys propensity to abuse his power and did nothing to stop Hadleys
illegal conduct.
COUNT I
FEDERAL CONSTITUTIONAL VIOLATIONS AGAINST DEFENDANTS HOFFMAN,
HADLEY AND UNKNOWN EGG HARBOR CITY POLICE OFFICER[S]
Plaintiff hereby incorporates, in their entirety, each and every paragraph of this
Complaint and by reference makes said paragraphs a part hereof as if fully set forth herein.
60. Defendants Hadley, Hoffman and Unknown Egg Harbor City Police Officers
committed the above described actions and/or omissions under the color of law and by virtue of
their authority as law enforcement officers for Egg Harbor City, and substantially deprived
Plaintiff of her clearly established rights, privileges, and immunities, guaranteed to her as a
citizen of the United States in violation of 42 U.S.C. 1983, and deprived Plaintiff of her rights
guaranteed to her under the Fourth, Eighth, and Fourteenth Amendments to the United States
Constitution, including but not limited to:
a. freedom from unlawful search and seizure;
b. freedom from unlawful arrest and seizure of her person;
c. freedom from coerced sexual abuse;
d. freedom from deprivation of liberty and property without due process of law;
e. freedom from summary punishment;
f. freedom from State created danger; and
g. freedom from arbitrary government activity which shocks the conscious of a
civilized society.
61. As a direct and proximate result of the acts and omissions of defendants Hadley,
Hoffman and Unknown Egg Harbor City Police Officer[s], Plaintiffs constitutional rights were
violated and Plaintiff was injured and sustained substantial injuries.
COUNT II
FEDERAL CONSTITUTIONAL VIOLATIONS AGAINST EGG HARBOR CITY
Plaintiff hereby incorporates, in their entirety, each and every paragraph of this
62. Defendant Egg Harbor City is under a duty to supervise the members of the Egg
Harbor City Police Department and to ensure that the policing activities of the Egg Harbor City
Police Department are run in a lawful manner preserving to the citizens of Egg Harbor City the
rights, privileges, and immunities guaranteed to them by the Constitutions of both the United
States of America and the State of New Jersey.
63. Defendant Egg Harbor City permitted, tolerated, and acquiesced to an official
pattern, practice, and/or custom of its police officers, particularly defendants Hadley, Hoffman
and unknown Egg Harbor City Police officers of violating the constitutional rights of the public
at large, including the Plaintiff. In particular, the City of Egg Harbor City repeatedly failed to
supervise the Defendants and such consistent and repeated failure had a propensity to deprive the
citizens of Egg Harbor City, New Jersey of their constitutional rights and failed to take proper
action to protect the citizens of Egg Harbor City, New Jersey from defendants.
64. The actions of defendants Hadley, Hoffman and Unknown Egg City Police
officers were unjustified, unreasonable, unconstitutional, and deprived Plaintiff of her
constitutional rights in violation of the Fourth, Eighth, and Fourteenth Amendments to the
United States Constitution.
65. Defendant Egg Harbor City is directly liable for the Plaintiffs damages due to the
following policies, practices, or customs of the Egg Harbor Police Department, which were in
effect at the time of this incident and which were the underlying cause of the Plaintiffs injuries:
a. Egg Harbor City and the Egg Harbor City Police Department have a
permanent and well-settled practice or custom of allowing police officers (including Hadley,
Hoffman and unknown police officers) to effectuate arrests of vulnerable women where probable
cause is lacking for the purpose of gaining a sexual benefit from those women, falsely promising
that their charges will be dismissed if they cooperate and provide sexual favors to the officers,
thereby creating an atmosphere of illegal and unconstitutional behavior in deliberate indifference
and reckless disregard for the welfare of the public at large, including Plaintiff;
b. Egg Harbor City and the Egg Harbor City Police Department have a
permanent and well-settled practice or custom of allowing police officers (including Hadley,
Hoffman and unknown police officers) to use inappropriate and illegal groping of women
without fear of discipline, creating an atmosphere of illegal and unconstitutional behavior in
deliberate indifference and reckless disregard for the welfare of the public at large, including
Plaintiff;
c. Egg Harbor City and the Egg Harbor City Police Department have a
permanent and well-settled practice of allowing police officers (including Hadley, Hoffman, and
unknown officers) to falsely arrest and charge civilians without probable cause as a tool to
conceal their own illegal and unreasonable conduct, creating an atmosphere of illegal and
unconstitutional behavior in deliberate indifference and reckless disregard for the welfare of the
public at large, including Plaintiff;
d. Egg Harbor City and the Egg Harbor City Police Department have a
permanent and well-settled practice or custom allowing police officers (including Hadley,
Hoffman, and unknown officers) to make false statements as a tool to conceal their own illegal
and unreasonable conduct in deliberate indifference and reckless disregard for the welfare of the
public at large, including Plaintiff;
e. Egg Harbor City and the Egg Harbor City Police Department have a
permanent and well-settled practice of failing to protect the Citizens of Egg Harbor City from the
unconstitutional actions of their police officers (including Hadley, Hoffman, and unknown
officers) by providing officers who have obviously clear customs, habits and routines of illegal
and unreasonable conduct with female suspects with unsupervised access to such female suspects
in their policing activities and thereby creating an atmosphere of illegal and unconstitutional
behavior in deliberate indifference and reckless disregard for the welfare of the public at large,
including Plaintiff.
f. Egg Harbor City and the Egg Harbor City Police Department have a
permanent and well-settled practice of failing to protect the citizenry of Egg Harbor City from
the unconstitutional actions of police officers by promoting rogue police officers, by refusing to
investigate civilian complaints, and by convincing civilians not to file formal complaints with the
Internal Affairs Unit, and by creating an atmosphere of illegal and unconstitutional behavior in
deliberate indifference and reckless disregard of the welfare of the public at large, including the
Plaintiff.
g. Egg Harbor City and the Egg Harbor City Police Department have a
permanent and well-settled practice allowing police officers (including Hadley, Hoffman, and
unknown officers) with obvious and well-known drug addictions to continue to police the
citizenry of Egg Harbor City, creating an atmosphere of illegal and unconstitutional behavior in
deliberate indifference and reckless disregard for the welfare of the public at large, including
Plaintiff.
66. Defendant Egg Harbor City is directly liable for Plaintiffs damages due to the
following policies or customs of inadequate training, supervision, discipline, screening, or hiring,
which were in effect at the time of this incident and which were the underlying cause of the
Plaintiffs injuries:
a. Egg Harbor City and the Egg Harbor City Police Department failed to
adequately train and supervise police officers Hadley, Hoffmann, and other unknown Egg
Harbor Police officer regarding their compliance with the laws, policies, practices, customs
regarding probable cause determinations; treatment/abuse of suspects, arrest procedures, criminal
investigations; drug investigations, preservation of evidence, duties to be truthful, duties to
intervene; use of confidential informants, internal affairs procedures and such failure to train had
the obvious consequence of leading to constitutional violations in deliberate indifference and
reckless disregard of the welfare of the public at large, including Plaintiff;
b. Egg Harbor City and Egg Harbor City Police Department failed to
adequately monitor and evaluate the performance of its officers (including Hadley, Hoffmann,
and other Unknown Egg Harbor City Police Officers) and their compliance with the laws and
policies, practices and customs with respect to probable cause determinations; arrest procedures;
treatment/abuse of suspects/detainees, criminal investigations; drug investigations; preservation
of evidence; duties to be truthful; duties to intervene; use of confidential informants, and internal
affairs procedures; in deliberate indifference to and reckless disregard of the
public at large, including the Plaintiff;
c. Egg Harbor City and Egg Harbor City Police Department repeatedly and
knowingly failed to properly discipline its officers (including Hadley, Hoffman, and Unknown
Egg Harbor City Police Officers) with respect to violations of the law of the State of New Jersey,
the Constitution of the United States, and its own policies and procedures, creating a pattern,
policy, practice, custom or atmosphere where such illegal and unconstitutional behavior is
tolerated, condoned, and accepted by the Egg Harbor City Police Department in deliberate
indifference to and reckless disregard of the public at large, including the Plaintiff;
d. Egg Harbor City and Egg Harbor Police Department allow its officers to
engage in conduct that violates the constitutional rights of persons in custody, including
Plaintiffs, without fear of reprimand, discipline or termination, creating an atmosphere where
such unconstitutional behavior is ratified, tolerated, and condoned, in reckless disregard of and
deliberate indifference to the welfare of the public, including Plaintiff; and
e. Egg Harbor City and Egg Harbor Police Department knew that a code
of silence existed between and among their officers whereby officers would not report
misconduct of other officers to their superiors and failed to take steps necessary to break the
code of silence which includes, but is not limited to, properly supervising officers, properly
investigating critical incidents, holding officers accountable for misconduct and failing to report
misconduct, creating an atmosphere where officers violate the constitutional rights of the public
at large in deliberate indifference to and in reckless disregard of the constitutional rights of the
pubic, including the Plaintiffs.
67. Further, defendant Egg Harbor City is liable for the actions of defendants
Hadley, Hoffman and other Unknown Egg Harbor City Police officers under the doctrines of
agency, vicarious liability, employer-employee relations, master-servant, respondeat superior,
joint venture, contract and as a result of their non-delegable duty to provide officers who comply
with the constitutions and laws of the United States of America and the State of New Jersey.
68. As a direct and proximate result of the foregoing policies, practices, and customs
of Egg Harbor City and the Egg Harbor City Police Department, the violation of the
constitutional rights of the citizens of Egg Harbor were substantially certain to occur.
69. As a direct and proximate result of the foregoing policies, practices, and customs
of Egg Harbor City and the Egg Harbor City Police Department, Plaintiffs constitutional rights
were violated and Plaintiff was injured and damaged.
COUNT III
STATE LAW TORTS AGAINST DEFENDANTS HADLEY, HOFFMAN, AND OTHER
UNKNOWN EGG HARBOR CITY POLICE OFFICERS

Plaintiff hereby incorporates, in its entirety, each and every paragraph of this Complaint
and by reference makes said paragraphs a part hereof as if fully set forth herein
70. The acts, omissions and conduct of defendants Hadley, Hoffman, and other
Unknown Egg Harbor City Police officers constitute assault, battery, trespass, trespass to chattel,
false arrest, false imprisonment, malicious prosecution, conspiracy, slander, spoliation, failure to
intervene, negligent infliction of emotional distress and intentional infliction of emotional
distress.
71. As a direct and proximate result of the aforementioned acts and omissions of
defendants, Plaintiff has been injured and damaged.

COUNT IV
CONSPIRACY TO VIOLATE CIVIL RIGHTS
Plaintiffs hereby incorporate, in its entirety, each and every paragraph of this Complaint
and by reference makes said paragraphs a part hereof as if fully set forth herein.
72. Defendants conspired to violate the civil rights of Plaintiff by targeting her for
unwarranted violence; subjecting her to malicious prosecution; coordinating false stories and
reports against Plaintiff to incriminate her and rationalize violence and mistreatment toward
Plaintiff; coordinating theirs stories and rationalizations so as to conceal the extent of the damage
that Defendants perpetrated against Plaintiff.
COUNT V
PUNITIVE DAMAGES AGAINST DEFENDANTS HADLEY, HOFFMAN, AND OTHER
UNKNOWN EGG HARBOR CITY POLICE OFFICERS

Plaintiffs hereby incorporate, in its entirety, each and every paragraph of this Complaint
and by reference makes said paragraphs a part hereof as if fully set forth herein.
73. The actions and/or omissions of defendants complained of herein were unlawful,
conscience shocking, and unconstitutional, and performed maliciously, recklessly, fraudulently,
intentionally, willfully, wantonly, in bad faith, and in such a manner to entitle the Plaintiff to a
substantial award of punitive damages against defendants.
DAMAGES
Plaintiff hereby incorporates, in its entirety, each and every paragraph contained in this
74. As a direct and proximate result of the aforementioned actions and omissions of
the defendants, Plaintiffs was injured and damaged. The damages for which Plaintiff seeks
compensation from the defendants, both jointly and severally, include, but are not limited to, the
following:
a. emotional pain and suffering of a past, present, and future nature;
b. loss of enjoyment of life of a past, present, and future nature;
c. fright, fear, aggravation, humiliation, anxiety, and emotional distress of a
past, present, and future nature as a result of the injuries sustained as a
result of the illegal actions of defendants;
d. loss of earning capacity;
e. attorneys fees pursuant to 42 U.S.C. 1988;
f. punitive damages against applicable defendants;
g. pre-and post-judgment interest;
h. declaratory judgment and injunctive relief holding that the policies,
practices or customs of defendants, complained of herein are illegal and
unconstitutional;
i. preclusion of defendants Hadley, Hoffman, and other unknown Egg
Harbor City Police officers from serving in the capacity of law
enforcement officers; and
j. all such relief, both general and specific, to which Plaintiff may be entitled
to under the premises.
PRAYERS FOR RELIEF
Plaintiff hereby incorporates, in its entirety, each and every paragraph contained in this
WHEREFORE, PREMISES CONSIDERED, Plaintiff sues the defendants
both jointly and severally, for his personal injuries and prays for a judgment against the
defendants for compensatory damages solely in an amount to be determined by a jury as
reasonable and for all such further relief, both general and specific, to which he may be entitled
under the premises.
WHEREFORE, PREMISES CONSIDERED, Plaintiff sues defendants Hadley,
Hoffman, and other Unknown Egg Harbor City police officers for punitive damages in an
amount solely to be determined by a jury as reasonable and for all such further relief, both
general and specific, to which he may be entitled under the premises.
73. A JURY IS RESPECTFULLY DEMANDED TO TRY THE ISSUES ONCE
JOINED.
Respectfully submitted,
BONJEAN LAW GROUP, PLLC
1000 Dean St., Ste. 345
Brooklyn, New York 11238
(718) 875-1850
(718) 230-0582

By: s/ JENNIFER BONJEAN


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