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EGENV
EIRM, P. C.
1555 Zion Road, Suite 203
MCFADDEN LAW
Northfield,
New
Jersey
DEC
08225
609-601-2330
mcf addenlawf i rm"aaol. . com
Louis P. McFadden, Jr. (0798)
14
2015
E'OR EEE
1)'IERRY
ir.
IfIAI/rER,
Plainti ff,
1) COUNEI
OF
GT.oUCSSTER,
a State of
2 ) nARDEN
capacity,
COMPI.AN
T AIID
i,I,RY DE!4IIiID
capac
NATURE OE COMST,AINI!
The
PIa
inti ff,
this multi-action
for violation
of his civil
Fourth,
Eighth,
united
states
constitution
by
and
in retaliatory
Plainti.ff
filed
Salem County
at the
Correction Facility.
,IITRTSDTCTION At{D \rE}rIrE
made
violations
of
constitution
the
of
the
Plaintiff's
united
civil
states
rights
of
under the
America as
more
Ls
1n
proper is
U.
S.
C.
reside in this
District
Filed
District.
PIRTIES
1.
Plaintiff,
New Jersey
L25 Cemetery
08098. Thereafter,
Road.
Plaintiff
was
2.
State of
New
Jersey
1,25
08210.
Cemetery
3.
4.
employee
5.
of the
Sal-em CounEy
an
CorrectionaL Facility.
names
of
and
true identities
Plainti-ffs.
names,
These
fictitious
named defendant.s
and/or officials
Said ,John
Doe
claims in the event their true identities are revealed, and all
c1aims asserted against the named defendants are intended to be
At alI
was
the State of
New Jersey.
in
3.
Flled
At all
Raymond
Warden
SCCF.
was subjected
Correctional- officer
SCCF
.Tohnson.
Elbert Johnson's
commands
Officer
Elbert
Johnson
and
to
Johnson
a "faggot".
while
in his ce11 to face the walI and put his hands on this
head.
Plaintiff
Elbert
.lohn
Doe
(sl
.lohnson
A-Z
and
began
6.
during Plaintiff's
'7.
incarceration at
SCCF.
Plaintiff
Defendant Correctional
behavior of
assaultive
aggressive
Of
f.icer
(s)
written
and
John
officers.
No actj-on was taken regarding Plaintiff's
repeated
John
Doe(s) A-2.
9.
Plaintiff
order.
and
is
up" if Plaintiff
Elbert
Plaintiff
Plaintiff
upon
Case
1:
15-cv-07073-RBK-AMD Document
Filed
Aglz4lt5
Page 7 of 30 PagelD: 7
SCCF
Correctional
Of
was
fj-cer
Elbert Johnson.
1)
crisis
support the
Plaintiff
forensic medical
:n"
examination process, investigatory j-nterviews; nor was
provided
PLaintiff
through
any
emotional
support,
crisis
investigation,
At all
SCCF was
terminated.
command
and supervisory
the
safety
of
all
inmates by,
maintaining a professionally
among other
things,
Raymond
corunand and
to meet the
more specifically
the Frj.son
Rape
New
and
(PREA)
intentionally,
not
to
adequate.Ly train
and
and by failing
to
educate, their
monitor their
effectlvely
procedures with
indifference
to
chose
force
del.iberate
said correctional
officers,
traininq
the
Jersey, and
the Plaintiff,
comnon
rights
Amendments
Plalntiff
alleges that,
New Jersey.
through its
Defendants maintaj,ned, or
deliberate
acted consistently
conducL,
with,
constiLutional ri ght .
71
said
and
such
official
New Jersey.
Skradzi-nski that
Plaintiff's
C,
of the
personnel.
and inadequacj.es of
training.
so as
to
create
Filed
an environment of
to],erance
and
rj-ghts.
The
ratified
and thereby
as alleged
herein.
24.
in
to establish,
facility
the correctional
policies
and procedures
offj,cers
and supervisors
2t.
indifferent
to
injuries.
of the Plaintiff.
offic.iaL
Terry
Eourth, Eighth
and
l0
s1983.
physicat
Walker, suffered
injury
and serious
and
Iikely suffer
the future,
statutory rights.
Furthermore, Plaintiff,
and
Terry Walker
of
the Plaintiff
Raymond C.
damagesi
b. attorney' s fees;
c. interest and costs of suiti
and
deems
corrNt
trc, - (42 u. s. c
s1983)
John
rights
Amendments
of the Plaintj,ff,
Terry
and
Ameri-ca.
rights
Terry Walker,
.fohn
an
illegal
Plaintifff
of his civil
Amendment to
retaliating
Defendants believed to
of
Correctionaf
be Plaintiff's
the correctional
Officer
and
cri-ticism
Doe
Elbert
for
what the
complaints
and Defendant
officers
Johnson and
Defendant
and
an
Officer
Elbert
Johnson and
by Defendant Correctional
Defendant correctional
but rather
was
causing harm.
The
aforesaid
actions
by
Defendants constituted
1 Filed 09l24lt5
Page 14 of 30 PagelD: 14
(s) A-2, in
of
violation
Plaintiff's
ic:er (s ) John
civil
rights
Of f
by Defendants, Plaintiff,
which
Plaintiff
endure great
emotional
and
suffer
the future,
statutory
rights.
Furthermore, PLainLiff,
Terry
and
WaIker
of solitude
L4
IiHEREFORE,
the Plaintiff
damagesi
b, attorney' s fees;
c. interest and costs of suit;
and
deems
corn[8 IEREE
33.
fi:Ily
set forth
herein.
34.
to
retaliate
against
Plaintj"ff
protected
constiEutionally
right,
for
exer:cising
specificaLly
filing
John Doe(s)
A-Z .
35. The
actions
aforesaid
participation
in
an
by
unlawful
15
Defendants constj-tuted
conspiracy,
with
the
of
Plaintiff's
civil
John
rights
America.
Terry
J.
WaIker, suffered
and
likely
wj,11
and damages in
constitutional
the future,
and statutory
Eurthermore,
Plaintiff,
difficulty
and
was
the Plaintiff
Case
l-5-cv-07073-RBK-AMD Document
1:
Filed A924lL5
Page 17 of 30 PagelD: 17
Doe
capacity, jointly
indlvidual
and
several-ly f or:
damagesi
b. att.orney's feesi
c. interest and cosLs of suit;
and
deems
Counts
herein.
individual
.Tohn
capacity, constitute
depriving Plaintiff
was
77
39.
animus, but
also
Correctional
officer
gender bias
Elbert
John
John
and
as the
Defendant
Johnson and
Defendant
Doe
(s)
A-2,
rePeatedly
and
Amendments
Defendants, Plaj-ntlff,
serious.
lnjury,
Terry
J.
Walker, suffered
and
and
constitutional
the future,
and statutory
rlghts.
Furthermore,
Filed
ogl24ll5
Page 19 of 30 PagelD: 19
Plaintiff,
and difficulty
trauma
was
the Plaintiff
(s)
and
severally for:
a. compensatory and punitive
damages;
b. attorney' s fees;
c. interest and costs of suiti
and
- ({2
deems
U. S. C 51985)
fulIy
Counts
set forth
herein.
depriving Plaintiff
Raymond
had
and neglected to
Raymond
officer
correctional officer(s)
assault
of
retaliating
Plaintiff
Elbert
Johnson and
Defendant
the
purpose of
for Plaintiff's
and
Correctionaf officer(s)
John
effort
but rather
was
4'7. The
actions
aforesaid
participation
in
an
by
unlawful
conspiracy,
with
the
(s) A-2, in
viofation
of
Plaintiff's
civil
John
rights
Terry
DefendanLs, Plaintiff,
serious,
injury,
and will
J.
vlalker,
suffered
and
and
and damages in
constitutional
the future,
and
rights.
statutory
Furthermore,
Plaintiff,
difficulty
and
was
the Plaintiff
Terry J. Walker,
demancis judgment
Doe (s
) A-Z in their
capacity, jointly
individual
(s)
and
severally for:
a. compensatory and punitive
damages;
b. attorney's feesi
c. interest and costs of suit;
and
deems
22
51988)
Filed
civil
Plaintiff
entitl,ed
to
recover reasonable
WHEREFoRE,
the Plaintiff
j udgment
Defendants in their
and
deems
COI'NT SEI,EbI
52.
John
Plaintiff,
53.
Terry J. WaIker.
and
individual,
capacity,
painful
suffered
Terry J.
the Plaintiff,
permanent injuries,
which required
in the future
Iikely
Plaintiff
walker,
his
and
and
and
was
deprived of
was
and statutory
consti-tutional
Furthermore, Plaintiff,
Terry J'
rights.
of solitude confinement
the Plaintiff
Efbert
Officer
Doe
Johnson
and
damages;
b. attorney' s fees;
c. interest and costs of suiti
and
deems
IIGEI
(ltcqll.iE nt P.r.on.l Iplua-y)
54. The allegations of fact set forth in the preceding Counts
COI'IIT
herein.
was
negligent.
was
grossly negligent.
57. At all times relevant to said batEery of the PLaintiff,
said
in
the
scope of
the
their
employment.
and
their
capacities,
Plaint.j.ff,
and in
Terry
,J.
which required
in the future
wj.ll
likely
Plaintiff
was
and
was
deprived of
his
likely
and statutory
constitutional
Furthermore, PlainEiff,
Terry J.
rights.
of solitude confinement
damagesi
b. attorney' s fees;
and
deems
COT'NI! NINE
Counts
set forth
herein.
County
and in
Terry J. Walker.
Terry J.
which required
in the future
will
likely
Plaintiff
was
and
was
deprived of
his
Iikely
constitutional
and statutory
rights.
of
confinement during
hi-s
his
and difficulty
incarceration
solitude
the Plaintiff
damages;
b. attorney's fees;
c. interest and costs of suit;
27
and
Case
1:
15-cv-07073-RBK-AMD
Document
as
the court
COI'NT
(New
deems
r}I
fully
Counts
set forth
herein.
63.
civil-
Terry J.
which required
in the future
wj-II likely
was
and
and
was
likely
28
deprived of
his
Eurthermore, Plalntiff
J'
Terry
rights.
and statutory
constitutional
l{alker
suffered
the
of solitude confinement
the Plaintiff
damages;
fees i
and
deems
colrN!! ELE\rE![
Counts
set forth
herein.
conduct by
the
Defendant County of
Skradzinski,
correctional officer
and in
the Plaintiff,
Terry J. WaIker
demands judgment
damages;
b. attorney's feesi
c. interest and costs of suit;
and
deems
McFADDEN LAW
FIRM, P.C.
20L5
30
(0798)