DONALD WINANT; _

MICHAEL LICAMELI;
: SUPERIOR COURT OF NEW JERSEY
: BERGEN COUNTY
JOHN ECKEL Plaintiffs
V.
: CHANCERY DIVISION
: DOCKET NO:
: Civil Action
+"^
THE BOROUGH OF DUMONT
VERIFIED COMPLAI
Nt
and COUNCILMAN CARL MANNA(Official,
Capacity) CARL MANNA(Individual Capacity); :
COUNCILMAN ELLEN ZAMECHANSKY
(Ofcial Capacity); ELLEN ZAMECHANSKY
(Individual Capacity); COUNCILMAN
MATHEW CARRICK Ofcial Capacity);
MATHEW CARRICK (Individual Capacity);
COUNCILMAN KENNETH FREEMAN
(Ofcial Capacity); KENNETH FREEMAN
(Individual Capacity); COUNCILMAN
HAROLD ST\iNOU(OficiaICapacity);
HAROLD STYLIANOU (Individual Capacity);
COUNCILMAN MARTIN CASP ARE
(Oficial Capacity); MARTIN CASP ARE
(Individual Capacity) GREGG PASTER, ESQ
Defendants
COMPLAINT
. `
.1
\... ~
Plaintiffs, Donald Winant, Michael LicameIi, and John Eckel(hereinafter "the Plajntiffs")
by and through their attorney, Frederic C. Goetz., Esq .
.
hereby bring this Complaint against
Defendants, Borough of Dumont, Councilpersons Carl Manna, Ellen Zamechansky, Mathew
Carrick, Kenneth Freeman, Harold Stylianou, Martin Caspare, Gregg Paster, Esq., all in their
official and individual capacities, respectively, aver as follows:
INTRODUCTION
1. This is an action for a declaratory, injtllction, monetary and other appropriate relief
, is brought by plaintiff to redress the violations of USC V, Statutes and Public Policy of the
State of New Jersey peretrated by Defendants of the rights secured to them by the laws of the
State of New Jersey
.
PARTIES
2. Plaintif
.
, Donald Winant, Michael Licameli, andJohn Eckel at times relevant
hereto, are residents of the Borough of Dumont.
. The Borough of Dumont a public entity operating under the laws of the
State of New Jersey.
4. Defendants, Carl Marma, Ellen Zamechansky, Mathew Carrick, Keneth
Freeman, Harold Stylianou, and Martin Caspare were at all times relevant hereto
Council Persons of the Borough of Dumont and known residents of Dumont.
5. Gregg Paster is a licensed attorey in the State of New Jersey and is the Borough
Attorey for Dumont
.
Preliminar Statement
6. Approximately over the last 13 years, defendants either directly or indirectly or
through the actions of tleir agents or known associates, have participated in a scheme to damage
the reputations and credibility of the plaintiffs for defendants own political gain or the gain of
their agents or known associates in an effort to distract the public from their failings as public
officials.
!. Defendants scheme stems out of a 20 year old controversy concerng soil
contamination at the Department of Public Works building in Dumont. During the years the.
Departent of Environmental Protection (Hereinafer "DEP") has cited the Borough for
violations of numerous laws and regulations. The defendants, for their own beneft or for the
benefit of their associates have falsely tried to blame the plaintifs for the problems they and/or

their associates originally created. Now through the improper use of their oficial ofice and
under the color of law they have tried to further their scheme. This time however they have gone
too far as they have slandered the plaintiffs, deliberately lied to the public, abused their authority,
violated the public policy of the Sate of New Jersey, and violated the public trust they hold to the
. citizens of Dumont in an effort to try and perpetuate their own political power.
8. On November V, 2010 all the defendants but Caspare and Paster improperly voted
for a resolution to authorize an investigation into the DEP issue. They specifcally attempted to
grant subpoena power to the entire Council of the Borough.
V. On January 12,2011, plaintiffs' attorey, Robert Galantucci, wrote to defendants'
hand picked Borough Attorey defendant Gregg F. Paster, and informed him of his incompetence
in drafing the resolution. He advised him that he did not follow the law. Specifically he failed to
follow N.J.S.A 40:48-25 which requires that the authority they sought could only be exercised by
a c011ittee that they must vote to establish. Paster still billed the Borough for the work he did
drafing the resolution.
10. On AprilS, 2011 the defendants fixed their attorey's incompetence and adopted
a Resolution drafed by defendant Paster establishing the formation of an "Ad-Hoc C011 ittee to
Investigate in Re DPW Environmental Remediation." This time-his incompetence was

substituted by a deliberate, wanton, reckless act. The resolution contains a lie to the public.
Specifcally, the third clause of the resolution states:
Whereas, certain individuals are unwilling to voluntarily provide
testimony, to wit, former Councilman Michael Licameli, former
Mayor/Administrator John Eckel and former Mayor Donald
Winant, whose testimony is critical to successful completion of the
investigation . . ..
11. The clause stated above falsely states that the plaintiffs were unwilling to
voluntarily give their testimony.
12 At no time did defendant Paster or any of the defendants request that the plaintiffs
voluntarily come to the committee and testif before it. .
13. Defendants wantonly and recklessly place that statement into the resolution to
justif to the public the need to create the committee and therefore lied to the public.
14. Defendants knew the statement was false, but proceeded anyway.
15. Defendants used their ofcial authority to promulgate their false statement to the
public to further their own purposes, not the public interest.
16. Using public resources and their ofcial authority they voted to create the
committee and grant subpoenas power to defendants Carrick, Stylianou, and Zamechansky.
!. Defendants committee took no action all summer long and fnally sought to act as
the 2011 election cycle took shape.
18. In an article that appeared in the Bergen Record on Tuesday September 20, 2011
defendants propagated the lie they knowingly voted on. The relevant portion of the article states:
Borough Attorey Gregg Paster said last week that about 12
current and former borough employees and elected offcials have
4
given statements about the contamination. Some provide testimony
voluntarily, while others were subpoenaed, he said. Winant, who
served as mayor from 1992 to 2003, Eckel and Licameli were
subpoenaed because they were among those who did not volunteer
information to Paster, Manna said.
19. Under the color of law defendants first issued subpoenas to the plaintiffs in late
2010. Then again sometime in August 2011 just before the election cycle.
20. Subpoenas require the plaintiffs to appear and give testimony and bring
documents based on a false statement and essentially threaten the freedom of the
plaintiffs.
21. Because the subpoenas were issued under false pretences they are not enforceable.
22. Just before the election cycle without a resolution the defendants removed
committee member defendant Stylianou and installed defendant Manna on to the
committee.
23. Defendants actions are wanton, reckless, deceitful, to further their or their
associates personal interests, not for public policy purposes.
24. As a result of defendants' actions plaintiffs had to employ two attoreys to
respond to their illegal SUbpoena.
COUNT I
Violation of Public Trust and Policy.
25. Plaintiffs, incorporate all the facts contained as set forth in the Preliminary
Statement and paragraphs 8 though 24 as if fully set forth herein.
26. The actions of the defendants have violated the public trust and public policy of
5
the State of New Jersey as set forth in the common law and in N.J.S.A. 40A:9-22.
et. seq.
27. As a direct and proximate result of Defendants' actions, Plaintiffs have suffered
damages.
WHEREFORE, Plaintiffs, Donald Winant, Michael Licameli, and John Eckel
respectfully request this Honorable Court to:
a. Enter a declaratory judgment that Defendants' acts of lying in a public
resolution for the purpose of issuing subpoenas
have violated and continue to violate the rights of plaintiffs as secured
by federal and state legislative enactments and the common law,
public policy and the United States and New Jersey Constitution.
b. Enjoin Defendants from harassment or any other retaliatory action
toward Plaintiffs in the fture.
c. Award plaintiffs compensatory damages including, but not limited to,
pain, suffering, emotional distress, past economic loss, fture economic
loss, back pay, front pay, loss of life's pleasures, loss of reputation, loss of
benefits, medical expenses and other damages;
d. Award reasonable costs and attorey's fees;
e. Award punitive damages, and;
f. Grant any other relief this Court deems just and proper under the
circumstances.
6
COUNT II
+& U.S C. I983
28. Plaintiffs, incorporates all the facts contained as set forth in the Preliminary
Statement, paragraphs 8 though 27 including Count as if fully set forth at length herein.
30. The actions of the defendants were pursuant to the policy of the State of New
Jersey which also for the formation of ad hoc committees with the power of subpoena.
31. Commanding the plaintiffs to appear before them were pursuant to acting in their
ofcial capacity under the color of law. The actions of Defendants have created and create to
create a retaliatory hostile work environment in violation of CEP A.
WHEREFORE, Plaintiffs, Donald Winant, Michael Licameli, and John Eckel
respectfully request this Honorable Court to:
a. Enter a declaratory judgment that Defendants' acts of lying in a public
resolution for the purpose of issuing subpoenas
have violated and continue to violate the rights of plaintifs as secured
by federal and state legislative enactments and the common law,
public policy and the United States and New Jersey Constitution.
b. Eroin Defendants from harassment or any other retaliatory action
toward Plaintiff in the future.
c. Award plaintiff compensatory damages including, but not limited to, pain,
suffering, emotional distress, past economic loss, future economic loss,
back pay, front pay, loss of life's pleasures, loss of reputation, loss of
7
benefits, medical expenses and other damages;
d. Award reasonable costs and attorey's fees;
e. Award punitive damages, and;
f. Grant any other relief this Court deems just and proper under the
circumstances.
COUNT III
Violation of Civil Rights N.J.S.A. 10:6-2 et. seq
32. Plaintiffs, incorporates all the facts contained as set forth in the Preliminary
Statement, paragraphs 8though 21 including Counts and I I as if fully set forth at length herein.
33. Defendants actions using the color of law based on known false statements is a
violation of plaintifs civil rights.
34. As a direct and proximate result of Defendants' actions, Plaintiffs have suffered
damages.
WHEREFORE, Plaintiffs, Donald Winant, Michael Licameli, and John Eckel
respectfully request this Honorable Court to:
a. Enter a declaratory judgment that Defendants' acts of lying in a public
resolution for the purpose of issuing subpoenas
have violated and continue to violate the rights of plaintiffs as secured
by federal and state legislative enactments and the common law,
public policy and the United States and New Jersey Constitution.
b. Enjoin Defendants from harassment or any other retaliatory action
toward Plaintiffs in the future.
8
c. Award plaintiff compensatory damages including, but not limited to, pain,
suffering, emotional distress, past economic loss, future economic loss,
back pay, front pay, loss of life's pleasures, loss of reputation, loss of
benefts, medical expenses and other damages;
d. Award reasonable costs and attorney's fees;
e. Award punitive damages, and;
f. Grant any other relief this Court deems just and proper under the
circwnstances.
Count IV
Defamation
35. Plaintiffs, incorporates all the facts contained as set forth in the Preliminary
Statement, paragraphs 8 though 34 including Counts I, II, and III as if fully set forth at length
herein.
36. Defendants statements in the Bergen Record are false and were knowingly made
false with a wanton, reckless disregard for the truth with the intent to paint the plaintifs in false
light.
37. As a direct and proximate cause of defendants statements plaintiffs have suffered
damages.
38. The plaintiffs further state that said words so spoken by the defendant were and are
utterly false, malicious and slanderous.
9
39. By reason of the acts of the defendant aforesaid, in and about the speaking and
publishing of the said false, malicious and slanderous words and statements, the plaintiffs were and
are greatly and permanently injured and damaged in their good names and reputations, and were
exposed to public contempt, hatred and ridicule, and have been fther damaged.
WHEREFORE, Plaintiffs, Donald Winant, Michael Licameli, and John Eckel
respectflly request this Honorable Court to:
a. Enter a declaratory judgment that Defendants' acts of lying in a public
resolution for the purpose of issuing subpoenas
have violated and continue to violate the rights of plaintiffs as secured
by federal and state legislative enactments and the common law,
public policy and the United States and New Jersey Constitution.
b. Enjoin Defendants from harassment or any other retaliatory action
toward Plaintiff in the future.
c. Award plaintiff compensatory damages including, but not limited to, pain,
suffering, emotional distress, past economic loss, future economic loss,
back pay, front pay, loss of life's pleasures, loss of reputation, loss of
benefits, medical expenses and other damages;
d. Award reasonable costs and attorey's fees;
e. Award punitive damages, and;
f. Grant any other relief this Court deems just and proper under the
circumstances.
10
COUT V
Defamation Per Se
40. Plaintiffs, incorporate all the facts contained as set forth in the Preliminary
Statement, paragraphs 8 though 39 including Counts [, , and [Vas if fully set forth at length
herein.
41. The defendants' statements published in the Bergen Record in the County of Bergen
to the public at large were maliciously spoke and published of and concerning these plaintiffs,
certain slanderous, false, malicious, scandalous and defamatory words, to wit:
Borough Attorey Gregg Paster said last week that about 12
current and former borough employees and elected officials have
given statements about the contamination. Some provide testimony
voluntarily, while others were subpoenaed, he said. Winant, who
served as mayor from 1992 to 2003, Eckel and Licameli were
subpoenaed because they were among those who did not volunteer
information to Paster, Manna said.
42. The words aforesaid tended to blacken and injure the honesty, integrity, morality and
reputation of the plaintiffs and to thereby expose then to public contempt and ridicule, and to injure
and damage their business.
43. _ The plaintiffs further state that said words so spoken by the defendants were and are
utterly false, malicious and slanderous.
44. By reason of the acts of the defendants aforesaid, in and about the speaking and
publishing of the said false, malicious and slanderous words and statements, the plaintiff s were
11
.
.
.
.
.
and
il'
egra
t
ly
:
and ,--..:.,.-,..ad da
a
d in :|....+-.:and reputations, ad
,

,
.
`
.
. .
'
werand ae expose'd to public contempt, hatred and ridicule, and ave been further dam
a
ged in
I0IIsaid business .
' .
WHEREFORE, the plaintiffs respectfully demand judgment against the defendants for
damages, toge.terw. i.timerest and
.
costs of suit.
. , -

t
Respectfully subriitted,

THE LAW OFFICE OF FREDERIC C. GOETZ, ESQ., LLC

.
;,.
.
.`:

Frederi
7
.
c Goetz., Esq.
Attor
q
y for Plaintiffs
.

_
.
' .
.

. .
' J
RY TRIAL DEMAND.
.
.
.
.
.
Plai
n
tifs he.f;;a tial by ]on al
'
{s::...-|-.

,
.
,

THE LAWOFFICE OF F",C C.GOETZ, ESQ;, LLC .

BY:
- 1` `
. _ _

_

DATED: +:/a-/::

,
: .`:.`

. -
.
VERIFICATION
The undersigned, offll age, in lieu of oath or affidavit, hereby certif and say:
1. We are the plaintiffs in the foregoing Verified Complaint.
2. We have read the foregoing Verified Complaint and aver that the facts contained therein
are true to the best of our personal knowledge and belief
13
NC

CCn!;l|ul u tc,U!u,SlulCmCul8mudCbI8 uIClluC. C ufCuW8ICllul I!uuU!

luC!UIC_U!u_8lulCmCul8mudCOI8u!CWI!I!u8C, WCu!C8IOjCCl lUIu!8lmCul.
9n Jz1
Unud !uuul
LulCd: l' / .
CERTIFICATION
II8IuullU IC4:51, llCIudCI8!_nCu,Ul!Iu_C, lC!COCCIl!I:C8llul`
2.
3.
+
umuuullUIuCU! llCblulCU!`CWJCI8Cund umllCullUInCIIuCIuCluI_Cd
W!lll8udu_ lu{8 mullCI;

`
. '
OllCOC8!UImKuUWCd_Cuud0!U!mul!Uu,llCW!llu uClIUu!8 uUlllC8IO]CClU!
uuUllC!uClUu Cud!u_!nunLUIIl,UIuuuIO!lIul!Uu!UCCCdu_8CUnlCmulCd
UllCOC8lUJmKHUWCd_Cuud IH!UITulUu,llClC8CuUUllClulL!C8 WlU8lUIId
OC]U\nCdin ll\80Ol\UnulllI8l\mC, uud

l!8 LCIl!I:Cul!Uu !8 IUV!dCd Il8Iuul lU llC ICgIIICmCul8 U! IC4:5-1.
I uClCOCClL!]!lulllC!UIC_U!u_8lulCmCHl8mudCO C8IClrIC. 8uW8rCl8l\!unU!
zu

" ' ~=

corsta ; mc arc wiIluIlyfalsc,8 sub]cctto pishmcnt.

DATED:. I1IOlI1

_ ` . . _
_
-

THE LAW OFFICE OF FREDERIC C. GOETZ, ESQ., LLC
' BY:
FIcasc 1kcnoc msuantto Rulc 4:25-4, Ircdcrc C. Ooctz, Jsquirc s hcrcby
dcsigatcd asmacclimeabcvc-captoncdmattctotLchaIfofthc!Iantff(s).

/
THE LAW OFFICE OF FREDERIC C. GOETZ, ESQ., LLC
BY:

.
'
rcC.Coctz,tsq.
ttofor]|ait:tffs
_
_ __
._; _ _ __ _

. _
lA1Fl :|:-/
'. __
;

_
*<
MER AY8
CARCK

CMM

z
M
J
WU
v
Z
/
MYUkMH
TUT c
Ofered by:
Seconded by:
2I0
UlHl1lHl1O1lNT
bl11lN
NAY ABAD ASE
.
..
- .
1
Reolution No.
285

Date:
November 9, 200
Psge.
lof 2

Subject:
Ivetgation and Subpoena
pO'er ,related to DPW
Environme:al Remediaton
rgc!
Authoraton
Account No ..
Contractll o. ,.,
Dollar Amount:

PreparedJ:
.
Greg Paster, Esq.
Certed a tue copy of a Reolution adopted by the Borough of Dumont on above
date ata Reular Meetng by: ,
,
Susan Connelly, RMC, Borough Clerk
Borongh of Dumont, Bergen Coun
t
, New Jersey
AUORIZATON OF IESTGATON ASOENA POWER RELATE TO
DPW ENVRONNTAL REDIATON "
RESOLUTON OF TH BOROUGH OF DUMONT
COUNTY OF BERGEN" STATE OF NEW JEREY
WR, the evmbody maUtorzed investgaton into cm cxand actons
mmcmYommm q cuc a set forth in d lettr dated Eetember z,zu!u
fom the New Jesey Deaent of Environment Protection; ad
Y, the mvg+UoD toquiros +cc|:|ar+l1rtam+ue;,including document rcqnosts and
subpoenas; 80
WRS, the Borough Council of oBoroug of Dumont now sees to execise its powers
80ttathe New Jersey Contuon, aplicable 8 and case law interretatons to issue
su!enas to compel tetimony 8 producton of documents as required to complete the
mvesUg+Uar.
NOW, THRFOR, BE IT RSOLVD by the Council of the Borough of Dumont, County
'of Bergen, State of New Jeey tat te Borough Attomey ad is heeby authorized to isue
subpoenas 0 tesn/cmm and/or subpoeas daces tecam D the name afthe Boroug of
Dumont, Q to 3 8 temony. and' producton of docmet 8 things as may D
necessar to complee te authorized investgaton.
1hereby cete foregoing to be a Tcopy aa resoluton adopted by te BeteuetOert
Coucil at a meeng held on Novebe +,zuu.

BOROUGH OF DUONT
BY.
ATST:
#&

46 L0
Dated: Noveber V,zu1u
-*
Gregg !. Paster, Esq.
|8 Railroad Ave., Suite I04
Rochelle Park, N 0bb2
Tel: (20J} 489~008
Fax: (20J} 489~0b20
Attorney for Borough of Dumont
IN RE DPW ENVIRONMENTAL
REMEDIATION
BOROUGH COUNCIL OF DUMONT
BERGEN COUNTY-NEW JERSEY
SUBPOENA A TESTIFICADU
THE STATE OF NEW JERSEY TO:
Michael Licameli
58 Wilcox Street
Dumont, NJ 07628
YOU P HEREBY COMDED to attend and give testimony at
the Law Offices of Gregg F. Paster Associates, 18 Railroad
Avenue - Suite 104, Rochelle Park, New Jersey 07662, on Friday,
January 14, 2011 at 11:00 A. M. with regard to the above entitled
action.
This subpoena is issued pursuant to a resolution of the
Dumont Borough Council dated November 3, 2010 and it concerns
New Jersey Department of Environmental Protection Case #90-05-
17-1528 (aka 90-05-17-1620, 90-03-08-1811, 91-09-12-1533) q
Failure to appear according to the command of this Subpoena will
subject you to a penalty, damages in a Civil Suit and punishment
for contempt of Court.
You are commanded to bring with you any documents, records,
contracts, applications, notes, memos, electronic data or other
physical mateials or things pertaining or related to the
alleged release of hazardous substances at the Dumont Boro DPW
Garage and nearby properties during the 1980s, 1990s and/or
2000s including, but not limited to, company policy on such
release of hazardous substances, identity of decision making
authorities, chain of command a d procedure to obtain permission
for such deposit.
Date: // [ql '
PASTER,
Attorney for Borough of Dumont
PROOF OF SERVICE
State of New Jersey}

County of Bergen
On , I, the undersigned, being over the
age of 18, served the within Subpoena by personally delivering a
copy thereof to the person named therein, at
And by tendering to such person the attendance fee of two
dollars ($2.00) as allowed by law.
Date:

CALAufucci C AfU1o
ROSERT L. G"LANTUCCI
JAMES P. PATUTO
PHILIP DE VENCENTES
JAMES O. ADDIS
DAVID J. A.LTIERI
PAUL H. HUQT
O COUH5EL
0anua 1, 011
Gzegg P. PaaLez, Bag.
COO~SLLOPS AT LAW
18 Ra11Wa AVenue 8u1Le 104
1y rr_ zaeg 66
55 STATE STREET
HACKENSACK. NEW JERSEY 0760 I
120l} 6461100
FAX: (201) 3434639
Re1 8Oen& Ad TeaL1I1candm tO N1cb&e1 I1cm11
Deaz M+ PaaLez!
Tb Ou IOz ouz 1eLLez OI 0&nua 5, 011 zeg&zd1ng
Lbe amgOen& aeXed. T aOz 1I 1eLLez d1d nOL
c1az1I Wb&L <Oncema aze ~ nme1 Lbe Va11d1L OI Lb1a
amgOena ~ and T aIza1d LbaL Lbe COuc11* BeaO1uL1On
Wb1cb Ou baVe gzOV1ded LO w dOea nOL a11eV1&Le
cOncema.
11e Lbeze 1a nO geaL1On LbaL Lbe m1c1ga1 cOuc11
baa Lbe gOWez tO "1nVeaL1gaLe" IOz 1eg1a1aL1Ve guOaea, a
cOnco 1anL OI 1La gOWez LO 1eg1a1aLe. BOWeVez, guzauanL
LO N.0.8.A. 40!48~5, Lbe gOWez LO 1aaue auDgOenaa IOz aucb
1nVeaL1gaL1Ve acL1V1L dOea nOL e1Ong LO Lbe COuc11, uL
aO1e1 LO Lbe 1nVeaL1gaL1ng cmLLee OI meza OI Lbe
.. .Qqgq) 1nV eLedM1 Lb .Lb&L.au00+
L
/-4S.~P.
e
~ ,.
be aggo1nLed g Le COuc11, and Wben 1L b&a IOW11 dOn0
aO, "Lbe c0LLeB Wa$ue & aWgOen& LeaL1I1Cmdm Oz
amgoen& ducea Lecm, LO an gezaOn W1Lb1n L1a 8L&Le
Td. 8ee a1aO B. OI Bduc&L1On OI Un1On C1Lg V. Un1On C1Lg,
11 N.0. 8ugez. 493 (IaW D1V. 1970}, aII*d, 118 N.0. 8ugez.
435 (Agg, D1V. 1970}) B. OI TzaLee& OI Pzee P11c
I1bza OI Un1On C1Lg V. Un1On C1Lg, 11 N.0. 8ugez. 484
(Cb. D1V. 1970}, aII*d 116 N.0. 8ugez. 186 (Agg. D1V.
1970}. Ad, OI cOuzae, aucb amgOenaa, Wben Va11d1
.

* @ *
1aaued, aze zeLuzab1e Lo and beIoze Lbe "Co1LLee," noL
Lo Lbe Co1LLee'a aLLoze.
Aa Lo Lb1a 1&aL go1nL, 1ng1 &a Lo ouz aLaLua
ze1aLea Lo Lbe IuzLbez IacL LbaL Wb11e Lbe 1nVeaL1g&L1ng
co1LLee Wb1cb Lbe Couc11 maL eaLab11ab 1a noL Lbe
Couc11 1Lae1I; and Lbe co1LLee'a zo1e 1a ng Lbe
"1eg&1 aIIa1za" oI Lbe goVez1ng bod aa Lo Wb1cb Lbe
m1c1g&1 aLLomeg no11 gzoV1dea 1eg&1 &dV1ce &nd
g1d&nce. Tbua, 1n Lbe abaence oI & m1c1g&1 ozd1n&nce
agec1I1ca11 deacz1b1ng Lbe m1c1g&1 &LLoze'a oII1ce aa
LC1ud1ngtbd1gD1o &c aa 1eg&1dVt&cz Lo aucb
cm 1LLee, Lbe Couc11 maL aggo1nL a "agec1a1 couae1" Ioz
aucb guoaea. 8ee BV&nko V. DII, b M+O+ 8ugez. D (IaW
D1V. 1980}.
P1eaae adV1ae aa Lo WbeLbez ou W111 W1Lbdz&W Lb1a
amgoen& aL Lb1a L1w, oz 1n Lbe eVenL Lbe aLaLuLo
zeg1zeNenLa b&Ve been NeL, g1e&ae adgoum Lbe CmLLee
NeeL1ng uL11 b&Ve been gzoV1ded W1Lb eV1dence oI Lbe
aLaLuLoz zeg1zWnLa aeL IozLb.
Vez Lz1 ouza,
GACC

Y1
ALA~1UCCl O rA1U1U
COUNSLLORS AT LAW
CL:ucci C |:u:c
ROBERT L. GALANTUCCI
JAMES P. PATUTO
PHILIP DE VENCENTES
JAMES O. ADDIS
DAVID J. ALTIERI
PAUL R. HUOT
OF COUNSEL
January , 0!!
Gregg . Paster, Esq.
Railroad A venue
Suite !J
Rochelle Park, NJ 01
CO]~S6LLORS AT LAW
K! Subpoena Ad Testifcandum to Donald Winant
DPW Environmental Remediation
Dear N. Paster:
55 GTATE 5TREET
ACK^GACK. MEW JRGY 07601
(201) 646-1100
FAX: (201) 3434b3S
` "* ~ * +~^^ ~-s~,, = +=~
Please be advised that this firm has recently been consulted with regar to a purported
subpoena, which was served upon the above named person, commanding that he attend
and give testimony at your offce.
As you know, this firm also represents Michael Licameli with regard to the same issue.
The subpoena is purportedly based upon the Resolution of the Dumont Borough Council,
eroneously dated November J, 0!0. I remain concered about the validity of both
subpoenas to W.-LicaeH and to N. Winant, mC presume-iliat-tfeResolut-ien-whiGh------ - --*'
you have suggested supports the issuance of the subpoena is the same Resolution in
support of the subpoena for N. Winant.
As we previously expressed to you, although the Municipal Council has the power to
"investigate" for legislative purposes pursuant to statute, the power to issue subpoenas for
such investigative activity does not belong to the Council, but solely to an investigating
committee vested with that authority. The committee must be appointed by the Council
and that committee when duly formed may issue a SUbpoena. A validly issued subpoena
is retable to and before the "committee" and not the municipality's attorey or the
committee's attorey. It is not to be constued as a deposition.
K: Subpoena Ad Testifcandum to Donald Winant
DPW Environmental Remediation
January 26, 2011
Page 2
As you know, we have supported these various positions with cases as referenced in our
prior correspondence to you regarding the subpoena to Michael Licameli, said letters
being dated December 30,200and January l2,20.
Ter-ore,. we have advised N. Wint tat he under no obligation to respond ..to',&e ..... ""
subpoena based on the premise that you have suggested in your corespondence.
Additionally, N. Winant has requested that I ret to you the S2.O check offered in
support of that sUbpoena.
ayou.
Very tuly yours,
GALANTUCCI&PATUTO
BY:
ROBERT L. GALANTUCCI
RLG/ac
cc: Denald Winant
AJA~1UCCl O rA1U1C
COUNSELLORS AT LAW
HZH8R8 AYZ
CM CK
.
CASPARE
.
?R88HAh
u
MANNA
v
STYLJANOU
'
ZMECHANSKY
v
MAYOR MoHALE
TOTALS
:
Offered by:
Seconded by:
Z0II
UlHl1lHlO1lN1
Hbl11lN
Resolution No.
NAY A$TAN A8$ZNT
Date:
Page:
Subject:
Purpose:
Account No.
Contract No.
Dollar Amount:
Prepared By:
I0
April 5,20II
of 2
DPW Environmental
Investigation
Establishment of Ad-hoc
Committee
Gregg Paster, Esq.
Certifed as a true copy of a Resolution adopted by the Borough of Dumont on above
date ata Regular Meeting b _
Susan Connelly, RMC, Borough Clerk
Borough of Dumont, Bergen Count, New Jersey
ESTABLISHEMENT OF AD-HOC COMMITTEE TO INVESTIGATE
1L HL1PLP1LL1W
WEREAS, the goveming body has authorized investigation into the circumstances and actions
surrounding celiain envirornental spill cases as set forth in a lette! dated September 2, 2UiU
from the New Jersey Department of Envirorunental Protection; and
WHEREAS, the inves. tigation requires additional information, including document requests and
subpoenas; and
WREAS, certain individuals are unwilling to voluntarily provide testimony, to wit, former
I
'
CALAr+ucci C Afuo
ROBERT L. GALANTUCCI
JAMES P. PATUTO
PHILIP DE VENCENTES
JAMES D. ADDIS
DAVID J. A, LTIERI
PAUL R. HUQT
OF COUNSEL
October 11, 011
NchucI Licamel
8Wilcox Steet
Dumont, NJ 0bb
Donald Winant
1Magnolia Avenue
Dumont, NJ 0bb
Tm<L\1W 1 L1Y
K! DPW Environmntal Remediation Subpoenas
Michael LicameIi and Donald Winant
Dear Michael and Don:
EATE ETREET
MACKENEACK. NEW JEREEY 07601
(201) 646-1100
FAX: (201) 343-4639
Enclosedherewith please find copy of letter recently received in the above-captioned
matter. After you've had an opportunity to review the same, please contact me
immediately so that we can arrange an appointentandmake some decisions.
Thank you.
Very tuly yours,
RLG:dc
Ene.
GRGG F. PASTHR & ASSOCtAYBS
PTTORNEYS P LY
wwWPASTEBEBO.COM
GPL00 F. ABBM
AM| NJ & A
PA9TERA9T8R6.COH
MK0HAN Y OmLWBOM
AOMITED NJ N
MTOMLIN50NO''STERISQ.COM
M HA!LROAD AVHN1& SU176 !
HOCHELL8 |APK, NW JEPSSY O7UU2
EL (ZJ} 4UH-U7U FAX (ZO1] 4U=DZ
+
October 1 0, 2011
V'qu|armaj'and fax at (201)_]|@
HO0UL Galantucel
8l80!uOc| Patuto
DDNI8treet
HacKensacKj NJ0701
Hc. EnYronmental Remediation Subpoenas
Michael
LicameJl: Donald Winant
Dear Mr. Galantueei:
TkVEM V- KLI!NHAN
10MI'D NJ NY
OFCOUNAL
$KL$lN MAN.PAS P5O.COH
As you are aware, your clients Mihael Llcamell and Donald Winant remain
subject to subpoenas issued by the Dumont DPW |nvest|gatog Committee on
September 12. 2011. | am in receipt of your October J co||esonOence and read the
recent profle of the trial you are currently engaged in- While | am anxious to
accommodate your schedule. the Committee consists of a member who will be leaving
the council at the end of the year. As such. the Committee intends to pl0cd on
Monday, October 17. 2011 at 6:30 p.m. The Committee fully recognizes your clients'
constitutional right to counsel and to decline to testify In the b8UnUC UIcounsel of their
choosing. I can represent that If you or someone from your firm cannot attend that
evening, and you 8dV|8O accordingly, the Committee wil l not hold your clients in
cODl8mpt O| filure lOappear, but I cannot guarantee that thelr!est|monyw|I| be-
rescheduled. In !hl event, the Commitee may b0gin preparing its report of findings
and simply report !h8 Messrs. Winant and Licameli were unable to testify due to
scheduling diccl||es. | will. however. prevail upon the Committee to attempt to
accommodate you and your clients' schedules. but cannot guarantee anything In that
regard. To that end. if you give me some avai!ble dates. l will discuss them with the
000l660give your clients the 0ppor|cnil,lopul|re|rte||mon,|nh6 pU0l'0|60old
| unde|staHd that you have stated publicly that It Is you|0IhlO Ih0I Ih6I|m|g0
th0 Committee hearing Is designed to provide politial ammunition In suppor of this
Fall's lc!iOn. H0w0V0l, Ih0 0al.|8 IhI 0n0 NoV0lbe|begins, between the election,
League of Municipalities Conference, 08nksgiving and lh0 Christmas and Hanukah
+ I V+ V I I I I , Q I nil!
HV lJ.7
|+ L
<
hOllUaySC88OD8, there l8 8lnplynot 80OUgh v8|0l8 ||n6 to 0Ompl=I0 lU6Committee's
work by the end of the year.
Should
y
ou have an
y
further qJest|on |8g0l00g this maRUrj |686 elfree to
contact our ofice.
Very truly yours,
HLU I. |PcHASSOCIATES
fIMotd
|6g |. l8I6I
-H'0v

cc; DPW Investigator Subcommittee

Susan oDnell
y
g RMC-Borough l6|K
~-^"`
1
Gregg !. Paster, Esq.
Jt Railroad Ave. , Suite JA
Rochelle Park, N uJbb2
Tel: |2J( 4t9~t
!5` t2;} 4t9-!2
Attorney for Borough of Dumont
IN RE DPW ENVIRONMENTAL
REMEDIATION
THE STATE OF NEW JERSEY TO:
Donald Winant
177 Magnolia Avenue
Dumont, NJ 07628
BOROUGH COUNCIL OF DUMONT
BERGEN COUNTY-NEW JERSEY
SUBPOENA A TESTIFICADUM

`
` '
YOU P HEREBY COMDED to attend and give testimony
before the DPW Investigatory Committee at the Borough Hall of
the Borough of Dumont, 50 Washington Ave., Dumont, New Jersey,
07628 on Thursday, September 22, 2011 at 8:00 P.M. with regard
to the above entitled action.
This subpoena is issued pursuant to a resolution of the
Dumont Borough Council dated April 5, 2011 and it concerns New
Jersey Department of Environmental Protection Case #90-05-17-
1528 (aka 90-05-17-1620, 90-03-08-1811, 91-09-12-1533). Failure
to appear according to the command of this Subpoena will subject
you to a penalty, damages in a Civil Suit and punishment for
contempt of Court.
You are commanded to bring with you any documents, records,
contracts, applications, notes, memos, electronic data or other
physical materials or things pertaining or related to the
alleged rele\se of hazardous substances at the Dumont Boro DPW
Garage and nearby properties during the 180s, 1990s and/or
2000s including, but not limited to, comPany policy on such
release of hazardous substances, identity of decision making
authorities, chain of command and rocedure, obtain permission
for such deposit.
Date: Lt! !
G SQ.
Attorney for Borough of Dumont
PROOF OF SERVICE
State C1 New Jerse
`
County of Bergen
On I, the undersigned, being over the
age of 18, served the within Subpoena by personally delivering a
copy thereof to the person named therein, at
And by tendering to such person the attendance fee of two
dollars ($2. 00) as allowed by law.
0ate:
Gregg !. Paster, Esq.
Jt Railroad Ave., Suite IA
Rochelle Park, NO tt2
Tel: |2J} At9t
!5 |2;} At9~!2
Attorney for Borough of Dumont
IN RE DPW ENVIRONMENTAL
REMEDIATION
BOROUGH COUNCIL OF DUMONT
BERGEN COUNTY-NEW JERSEY
SUBPOENA A TESTIFICADUM
THE STATE OF NEW JERSEY TO:
Michael Licameli
58 Wilcox Street
Dumont, NJ 07628
YOU A HERBY COMDED to attend and give testimony
before the DPW Investigatory Committee at the Borough Hall of
the Borough of Dumont, 50 Washington Ave., Dumont, New Jersey,
07628 on Thursday, September 22, 2011 at 6:30 P.M. with regard
to the above entitled action.
This subpoena is issued' pursuant to a resolution of the
Dumont Borough Council dated April 5, 2011 and it concerns New
Jersey Department of Environmental Protection Case #90-05-17-
1528 (aka 90-05-17-1620, 90-03-08-1811, 91-09-12-1533). Failure
to appear according to the command of this Subpoena will subject
you to a penalty, damages in a Civil Suit and punishment for
contempt of Court.
You are commanded to bring with you any documents, records,
contracts, applications, notes, memos, electronic data or other
physical materials or things pertaining or related to the
alleged release of hazardous substances at the Dumont Boro DPW
Garage and nearby properties during the 1980s, 1990s and/or
2000s including, but not limited policy on such
release of hazardous substances, of decision making
authorities, chain of command an to obtain permission
for such deposit.
Date: q!I,[I\
G PASTER, ESQ.
Attorney for Borough of Dumont
7
/
I
PROOF OF SERVICE
State of New Jersey}
SS:
County of Bergen
On I, the undersigned, being over the
age of 18, served the within Subpoena by personally delivering a
copy thereof to the person named therein, at
And by tendering to such person the attendance fee of two
dollars ,2.) as allowed by law.
Date:
ALAN1UCCI AIU1C
Hx1UEHT L \LA^1L\ I
,mES P HATLTC
O)),tP QE V.)| [_
,\1> D . CQ:
HL H !OJ
.
` .> .
COUNSELLORS AT LAW
t\08iMiLE18AN8mI88ION8HFE1
1u:
l
!
lKOM:
. _~'1
DATL:
l-[~(
KL: "'
STArE STREET
HACKENSACK. NEW JERSEY 07601
,201,6461100
FAX' ,201' ,Q,-<,=
NUMRufrACSSNT(INCUuINCCuVRrAC)
MLbAUL:
If you do not receive all pages or have any problems receiving this fax, please call
(201)4-1I0008Kfor
POBERT L 0ALAN1QCCI
JAHCS PATUTO
CLuucc & Ftfuo
CTLMEELLCH> A LAW
STATE STREET
PHILIP DE VENCENTES
JAHS Q. ADDIS
HACKENSACK. NEW JERSEY 07601
DAVID J ALTIERI
PAO\ M. HUOT
c. ccu"Uc
OOCODBX 17 2011
UXBgg = PBCBX @
19 B&1JXO& VBDUB
BU1CB 1v4
BOCBJJB PXK; NeW 0BXBB 07662
BB1 OPN &V1XODBDC&J BBOB1&C1OD BOBD&B
M1C8BJ L1C$JJ1 DDDJ N1DDC
O0&X M+ V0BCBX1
(201) 6A61100
FAX, 12011 343'4639
T&DK OU IOX OUX JBCCBX OI OCCODBX 10, 2011. 8O
CBXB 1B DO O1BUBXBC&D1Dg ON0VBX CB BOBUJ1Dg
gXODJW &VB Wm BDC1XBJ XBJCB CO BCBUJB m DOC
tboae OI OJ1CB+ TB` XB0D XBN1D N1JJ1Dg CO IUJJ
OOOgBX8CB N1C CB LOW1CCBB*B 1Dg1X1BB. I 0D CB NOUJ
be ava1JabJe OD B CB 1D CB 6BCOD Week OI NOvBX 1I
O0 IBBJ CB1X CCBD&DOB 1B DBOBBBX
B CO CB &gg8XBDCJ gXBBB C1OB IOCOX D&BB OD ODB
O0W1CCBB OBODBX*B JB8V1Dg CB COUO1J, 2 NOUJ gO1DC OUC
C&C &JCOUg CB w1c1aJ CO0C1J OJB8XJ BCBXO1DB CO
1DVBBC1gCB C1B NCCBX 1D CB Y&JJ OI 2010. 1C NB DOC
WC1J gX1J 0 3011 CDC CB CO 1CCBB NB BBC8J1BB D
tbe CO0DC1Jy m DOC m1J BBgCWBZ , 2011 JBBB C8D CNO
WDCB DBIOX0 O01O1gJ BJBOC1ODB C&C CBCO 1CCBB
BUDQBDB NBZB 1BBUB CO C11BDCB, UDBXBUO
O1XOuBC&DOBB 1C 1B DOC UXB&BOD&DJB to BuggBBC C0C CB
0Xg0DO OI CB C1O1Dg &B DOC 1DO1BDCJ CO CB ugOO1Dg
eJeCC1ODB+
1D1C8CB W OJ1BDC8 IUJJ CO CCB CO
OOOgBX&C1Dg N1C CB CO 1CCB0 HONBVBX as I VB
1D0zO&CB pmI, LB aze 1D gOBBBBB1OD OI DO
-@-
docuents related to the operations or fuctioning of the
DP during their ters office. Dring those times, all
files were in the hands of the towship attorey and/or the
towship administrator, which are certainly available to
the Comittee. All inforation relating to the matters
being investigated was conveyed to clients, as well as
other mers of the mnicipal coucil, by the towship
attorey and/or.the top adinistrator, upon which
infortion and advice clients relied. N clients'
testimony therefore would relate solely to that inforation
and advice.
As indicated. clients are ready, willing and able,
to cooperate by testifying before the Comittee, or indeed
any other investigator boy, regarding the inforation and
advice provided to them by the towship attorey and the
towship adinistrator during the relevant time periods.
Please advise if the second week of Novemer is acceptable
to the Comittee.
Ver try yours,
GACCr & PATUO
X1
ROBRT L. GCCI
Via telefax/regular mil
ce: Michael Licamelli
Donald Winant
CALANIUcCi A1UIO
LCLfUE|LCU A LPW
A@@8HdX2II-1
LVL LPC NLNPLN PCNCN
C' S)
fOHUbbHY ULbHh'bOrrlUEUNLY
Use for Initial Law Division
PAYMENT TYPE: DCK DCG DCA
CHG/CK NO.:
Civil Part pleadings (not motions) under ul64.-1 .
AMOUNT:
Pleading will be rejected for filing, under Rule 1:5-6(c),
if information above the black bar is not completed or
if attorney's si gnature is not affi xed.
OVERPAYMENT:
BATCH NUMBER:
OFF[CE ADDRESS
! ! ! MUOSOD PV0.
. L.OX 44
lO@00lO, NJ 0
DOCKET NUMBER (when available)
DOCUMENT TYPE
LOR[Bl D
JURY DEMAND
NAME OF PARTY (e.g., John
lCapac|q),

ODBODBD lCOB0 LlCB0 l. Capaiq),
OO 0
Caa|q),
Capare IiaCaac) gg
[S TH[S A PROFESS[DNAL MALPRACT[CE CASE? NO CASE TYPE NUMBER
(See reverse side for listing)
[F YOU HAVE CHECKED " YES:' SEE N.J.S
.
A. 2A:S3A-27 AND APPLICABLE CASE LAW
0
RELATED CASES PEND[NG?
D YES NO
REGARD[NG YOUR [ TO F[LE AN AFF[DAV[T OF MER[T.
[F YES. LIST DOCKET NUMBERS
DO YOU ANT[C[PATE ADD[NG
ANY PARTIES (arising out of same
transaction or occurrence)?
NAME OF DEFENDANT'S PR[MARY [NSURANCE COMPANY. [F KNOWN
_ YES NO
7
_ NONE UNKNOWN
JHbINIOHMP1ION FHOVIObDONJHIB(OMCPNNOJUbINJHOOUCbOINO bVIObNCb.
CAbECHAHACbHlbTICb |H|U|bbbL|OcHMININL IF CASE IbA|HHHHIA|HMOlAIN
DO PART[ES HAVE A CURRENT,. IF YES, IS THAT
PAST OR RECURRENT . RELATIO.NSHIP
_EMPLOYER-EMPLOYEE _FRIEND/NEIGHBOR
_FAMILIAL

_BUSINESS
I OTHER [0k|8U).Eorm".
RELATIONSHIP? OYES [NO
too::va,oco:o.&&===
DOES THE STATUTE.GOVERNING THIS CASE PROVIDE
DYES NO
FOR PAYMENT OF FEES BY THE LOSING PARTY?
USE TH[S SPACE TO ALERT THE COURT TO ANY SPECIAL CASE CHARACTER[ST[CS THAT MAY WARRANT [ND[VIDUAL MANAGEMENT OR
ACCELERATED D[SPOS[TION:
161 \ 00
YOU OR YOUR CLIENT NEED ANY
DISABILITY ACCOMMODATIONS? .
W[LL AN INTERPRETER BE NE.EQED?
DYES [NO
[F YES. PLEASE IDENTIFY THE
REQUESTED ACCOMMODATION:
DYES NO
[F YES, FOR WHAT LNGUAGE:
C0llyD8CDHl00Rl8 0fSDR8 lO0Rl0ISR R f008C00 l0RODCUR0R8 RDW8UDRl0O D R0 CDUfl, 8R0 W D0
f0O8C00IDR8 ODCUR0R88UDR00 UR 8CCDI08RC0WlRu0 J

-[Dj.

ATTORNEY SIGNATURE
/'
F|006!l0L0OC2E8q.
Aun!tOrney8t|WOfN.
iU Iv!88eInIoIm8!|0n seait..
AenuL\X!-1,NIIY
h07

!I LIe0!v8YIl0 TI
Powe:ed cy
|OL|OC>
:u d A L- E V by L STAT LEGAL

A Dvb000ALL-STATE 0I8t08!008, !0c.

W .880_8.00m

o0..I0 a_ I
C| V| L C/SE | N|HM/1| NS1/1EMEN1
C| S)
Use for initial (not motions) under U|6 4.-1
LAUYHLU (Choose one and enter number of case type in appropriate space on the reverse side.)
Track 1 -150 days' discover
151 NAME CHANGE
175 FORFEITURE
302 TENANCY
399 REAL PROPERTY (other than Tenancy, Contract, Condemnation, Complex CommerCial or Construction)
502 BOOK ACCOUNT (debt collection matters only)
505 OTHER INSURANCE CLAIM (INCLUDING DECLARATORY JUDGMENT ACTIONS)
506 PIP COVERAGE
510 UM or UI M CLAIM (coverage issues only)
51 1 ACTION ON NEGOTIABLE INSTRUMENT
512 LEMON LAW
801 SUMMARY ACTION
802 OPEN PUBLIC RECORDS ACT (SUMMARY ACTION)
999 OTHER (briefly describe nature of action) _
Track II -300 days' discovery
305 CONSTRUCTION
509 EMPLOYMENT (other than CEPA or LAD)
599 CONTRACT/COMMERCIAL TRANSACTION
603 AUTO NEGLIGENCE - PERSONAL INJURY
605 PERSONAL INJURY
610 AUTO NEGLIGENCE - PROPERTY DAMAGE
621 UM or UIM Claim (includes bodily injury)
699 TORT -OTHER
Track III -450 days' discover
005 CIVIL RIGHTS
301 CONDEMNATION
602 ASSAULT AND BATTERY
604 MEDICAL MALPRACTICE
606 PRODUCT LIABILITY
607 PROFESSIONAL MALPRACTICE
608 TOXIC TORT
609 DEFAMATION
616 WHISTLEBLOWERICONSCIENTIOUS 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 ENVIRONMENTAUENVIRONMENTAL 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
Centrally Managed Litigation (Track IV)
280 lELNORM
285 STRYKER TRIDENT HIP IMPLANTS
288 PRUDENTIAL TORT LITIGATION
Mass Tort (Track IV)
248 CIBA GEIGY
281 BRISTOL-MYERS SQUIBB ENVIRONMENTAL
266 HORMONE REPLACEMENT THERAPY (HRT)
282 FOSAMAX
271 ACCUTANE
272 BEXTRNCELEBREX
274 RISPERDAUSEROQUEUlYPREXA
275 ORTHO EVRA
277 MAHWAH TOXIC DUMP SITE
278 lOMETA/AREOlA
279 GADOLINIUM
283 DIGITEK
284
NUVARING
286 LEVAQUIN
287 YAZYASMIN/OCELLA
601
ASBESTOS
619 VIOXX
If youb0II0V0thISC8S0 f0quI f0S 8tf8Ck oth0fth8n th8t pfoVId0d 8boV0, pI08S0|ndIC8t0th0f08Son on 8Id01 ,
|nth0Sp8C0 und0f"C8S0Ch8f8Ct0fIStICS."
|easececk ceacaa|cae|ecateqc,.
_Verbal Threshold
30 Civil Case Information Statement (CIS)
AppendixXII-Bl; LI10517
Rev. 7/1O Effective 7/1/10 P7/1O
_Putative Class Action
Poweed cy
|OL|OC>
o Tille
Printed by ALL-STATE LEGAL
A Division ofALLSTATE Intrnational, Inc.
ww .aslegal.com 800.222.0510 Page 2