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WURGAFT
HICKS KAHN WIKSTROM & SININS, P.C.

JAVERBAUM

Certified Trial Attorneys

505 MORRIS AVENUE
SPRINGFIELD, NJ 07081

Eric G. Kahn, Esq.

TEL: 9733794200

Managing Partner
Certified Civil Trial Attorney
ekahn@lawiw.com

FAX: 9733797872
www.lawjw.com

September 24, 2015

VIA CERTIFIED MAIL, R.R.R.
AND REGULAR MAIL
Department of Children and Families
20 W. State Street
P.O. Box 729
Trenton, NJ 08625-0729
Attention:
RE:

Administrator of Tort Claims

S
A.
by her Guardian ad Litem Linda Couso Puccio,
Esq.
Date of Incident: July 2012 through December 2012

Dear Sir/Madam:
Please be advised that this office has been retained to represent S
A.
, an infant by her Guardian ad Litem, Linda Couso Puccio, Esq. for
injuries/damages sustained as a result of incidents which occurred between
July 2012 and December 2012 or any other dates not yet determined.
Please
accept this letter as formal Notice of Claim pursuant to N.J.S.A. 59:8-1,
et seq. of the New Jersey Tort Claims Act. More specifically, and pursuant
to N.J.S.A 59:8-4, I am providing you with the following contents of my
clients' claim:
(A)

SPRINGFIELD

Name & Address of Client:

S
A.
, an infant by her Guardian ad Litem, Linda
Couso Puccio c/o Fiorello, Puccio & Fiorello
1044 Route 23 North
Suite 318
Wayne, NJ 07470

NEWARK

JERSEY CITY

FREEHOLD

MOUNTLAUREL

ENGLEWOOD

ELIZABETH

1 NEW YORK CITY

September 24, 2015

Page 2
{B)

Name & Address of Attorney:

Javerbaum Wurgaft Hicks Kahn
Wikstrom & Sinins
505 Morris Avenue
Springfield, NJ 07081
Attention: Eric G. Kahn
All communications from you should be directed to this address.

{C)
Date of Accidel).t & Location: between July 2012 and December 2012,
S
A.
, an infant, age 13 {Date of birth 12/23/1999), was a
resident of the New Jersey Mentor Pine Group Home, 21 Pine Drive, Millstone,
New Jersey 08844. While she was a resident, S
A.
was under
the care, custody and control of New Jersey Mentor, the Department of
Children and Families of the State of New Jersey, or under the Division of
Child Protection and Permanency of the State of New Jersey, which entities
were responsible for operation, management or supervision of the Group Home
in which claimant was a resident or which entities were responsible for
hiring, training and retaining persons employed at said Group Home, including
Lawrence Forman, a Direct Service Provider responsible for the care,
management, supervision and safety of residents of said Group Home.
Between
July 2012 and December 2012, and at any other times presently unknown,
Lawrence Forman, an adult, age 43, who, in his capacity as a Direct Service
Provider, was responsible for the care, control, management, supervision and
safety of residents of the Group Home improperly engaged in sexual contact,
sexual abuse and/or sexual exploitation of the infant, S
A.
.
Subsequently, in or about July 14, 2014, Lawrence Forman pled guilty to
endangerment of the welfare of S
A.
by sexual conduct in the
matter of State of New Jersey vs. Lawrence Forman, Superior Court of New
Jersey, Monmouth County, Law Division - Criminal Part, Indictment # 14-0100229.
{D)
Description of Injuries: As a direct and proximate result of the
improper sexual contact, sexual abuse and/or sexual exploitation, S
A.
sustained severe and permanent personal and emotional injuries.
{E) Responsible Parties: Public entities responsible for owning, operating
supervising and managing New Jersey Mentor Group Home where she was a
resident in Millstone, New Jersey, and those public entities responsible for
training, assessing, hiring, and supervising Lawrence Forman, a Direct
Service Provider, at said Group Home.
Upon information and belief, these
public entities include New Jersey Mentor, the Department of Children and
Families of the State of New Jersey, or the Division of Child Protection and
Permanency of the State of New Jersey.
In the event Lawrence Forman was
employed by any these public entities, claimant alleges that these entities
are responsible for his conduct and under the doctrine of respondant
superior.

September 24, 2015

Page 3

Finally, Plaintiff alleges that these public entities may be liable for
violations of the New Jersey Law Against Discrimination, N.J.L.A.D., for
failing to properly protect and supervised the minor claimant under its
custody and control.
(F)
Amount of Damages Claimed: At the present time, the amount of the
claimant is unliquidated in nature, however, it is alleged that claimant's
injury will qualify as permanent loss of bodily function or permanently
injury sufficient to satisfy N.J.S.A. 59:9-2.

Should you require any further information or should you have a claim
form which requires completion pursuant to N.J.S.A. 59:8-6, kindly contact
or supply the same to the undersigned.
Thank you for your kind attention to the above matter.

v2:;~'
Eric G. Kahn
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