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Werner
Strawbridge Professional Center
212 West Route 38; Suite 200
Moorestown, New Jersey 08057
(856) 380-4062
(609) 265-9637 (Fax)
_______________________________________
: SUPERIOR COURT OF
NEW JERSEY
EDWARD G. WERNER, LAW DIVISION
: MERCER COUNTY
INTRODUCTION
through July 16, 2008 he served as the head of the New Jersey State Government
Agency charged with
compensating innocent victims of crime. During his tenure in that capacity, the
agency had several
2007), the Victims of Crime Compensation Agency (July, 2007-July 2008), and the
Victims of crime
1
Compensation Office (July 2008-present). The statutes, administrative code, case
law, and other
and clarity, this Complaint will refer to it in its current form, The Victims of Crime
Compensation Office
(“VCCO”).
2. The Defendant, The New Jersey Department of Law and Public Safety,
(“L&PS”), is a public
agency of the State of New Jersey and is a principal department of the Executive
Branch of the State
on July 1, 2008.
5. Under statute 2C:43-3.1 the VCCO receives funds from assessments paid by
defendants in the
various criminal and municipal courts throughout New Jersey. These assessments
constitute a plurality
DIVERSION OF FUNDS
6. Attached as exhibit “1” is the Annual report of the VCCO for State Fiscal
Year 2009 (“SFY09”) i.e.
July 1, 2008 through June 30, 2009. According to page thirteen of said Annual
2
Report, VCCO revenues
for SFY09 totaled $22,914,759.91. Of that revenue, $9,580,000 came in the form of
federal grants
under the Federal Victims of Crime Act and $8,676,759.91 from New Jersey state
sources.
Penalty Revenue reports, even the incomplete response reveals the VCCO received
approximately
8. As more fully explained in the attached Brief, these funds by law may only
be spent to
9. According to page 6 the VCCO Annual Report for SFY09, the VCCO paid
only $5,561,608.21 to
10. As of March 31, 2009, the VCCO only reported receiving $2,181,648.72.
This figure includes
assessments and funds collected from prison and jail commissaries throughout New
Jersey. Obviously,
3
11. The amount paid to victims is historically very low. Below is a chart
comparing the volume of
work produced by the VCCO for SFY07 and SFY08 versus SFY09:
12. The financial statement reveals that the funds that were to have been
spent only for the
both the statutes governing the VCCO and of the criminal law (see attached brief).
13. In order to accomplish this diversion, the VCCO adopted policies to deny or
delay the payment
of claims. Below is a comparison of the payments to victims for SFY08 and SFY09.
4
Sexual 703 $896,138 Sexual 263 $366,54 -440 -$529,597
Assault Assault 1
14. The decision to alter VCCO policies to unreasonably delay and deny the
payment of crime
victims’ claims is not only devastating for the victims, it is detrimental to the
agency. The VCCO federal
grant is calculated by the federal government as the product of funds paid from
New Jersey State
sources other than tax revenue multiplied by 60%. Consequently, the future federal
grants will be
5
15. The Plaintiff has no response from Mr. Jeffries or anyone else from the
Department of Law and
has wrongfully diverted funds from innocent victims of violent crime in violation of
NJSA 2C:43-3.1;
B. Requiring the Department of Law and Public Safety to account for the
funds received from
assessments by defendants in courts throughout New Jersey for State Fiscal Year
2009;
C. Maintain jurisdiction over this matter until the Department of Law and
Public Safety comes into
E. Grant such other and additional and further relief to the Plaintiff as the
Court deems just and
equitable.
6
CERTIFICATION PURSUANT TO RULE 4:5-1
Pursuant to the provision of Rule 4:5-1, the undersigned pro se attorney and
Plaintiff certifies the matter is not the subject of any other pending action in any
other court or arbitration proceeding.
In the interest of full disclosure, the Plaintiff is also the Plaintiff in Case No. MER-L-
600-09 (Werner v. State of New Jersey, Milgram, and Jeffries).
___________________________
___
Edward G. Werner
Strawbridge Professional
Center
212 West Route 38, Suite
200
Moorestown, New Jersey
08057
(856) 380-4062
(609) 265-9637 (F)
Plaintiff Attorney Pro Se
7
VERIFICATION
I am the pro se Plaintiff in this matter. I have reviewed the foregoing Verified
Complaint in its
entirety and the statements made therein are true and correct to the best of my
personal knowledge.
DATED:
___________________________
Edward G. Werner
Plaintiff pro se