LaCorte, Bundy, Varady Kinsella 989 Bonnel Court Union, New Jersey 07083 (908) 810?0500 Attorneys for Plaintiff, Jane Doe JANE DOE (a fictitious name) Plaintiff, vs. HANOVER TOWNSHIP, HANOVER TOWNSHIP POLICE DEPARTMENT, JOHN SCHAUDER, individually, and in his official capacity as a police officer of the Hanover Township Police Department, STEPHEN W. GALLAGHER, individually, and in his official capacity as a Chief of Police of the Hanover Township Police Department, JOHN DOES 1?20, a ?ctitious name for presently unknown agents, members, commissioners, chiefs, representatives, or employees of the Hanover Township Police Department, individually, and in their official capacities. Defendants. follows: Case Document 1 Filed 10/29/09 Page 1 of 10 PagelD: 1 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY Civil Action No.: COMPLAINT and DEMAND FOR TRIAL BY JURY Plaintiff, Jane Doe (a fictitious name), by and through her attorneys, LaCorte, Bundy, Varady Kinsella, by way of Complaint against the defendants herein states, upon information and belief, as JURISDICTION AND VENUE U.S.C. 1331 and 1.43. 1. This action is brought pursuant to 42 U.S.C. 1983. Jurisdiction is based upon 28 Case Document 1 Filed 10/29/09 Page 2 of 10 PagelD: 2 2. The venue in this district is proper because, upon information and. belief, all defendants either reside in. or are located in the District, and all events took place in the District. PARTIES 3. Plaintiff, Jane Doe, is a competent adult, a citizen of the United States, and currently resides in Morris County, New Jersey. 4. Defendant, Hanover Township, (the ?Township?) is and was at all times relevant to this Complaint, a municipality organized under the laws of the State of New Jersey. 5. Defendant, Hanover Township Police Department (the ?Department?), is and was at all times relevant to this Complaint a division or department of the Township entrusted with certain responsibilities, among others, enforcing federal, state and local laws and ordinances, and otherwise insuring the safety of the people and property found within the jurisdictional limits of the Township. 6. Defendant, John Schauder (hereinafter ?Officer Schauder?), is a municipal employee in the position of police officer for the Department. 7. Defendant, Stephen W. Gallagher (hereinafter ?Chief Gallagher?), is a municipal employee in the position of chief of police for the Department. 8. John Does 1~20 are ?ctitious names for any and all presently unknown persons who were at all times relevant to this complaint agents, representatives and/or employees of the Department, who were involved or in any way responsible for the events described in this complaint. They are being sued both individually and in their official capacities. NATURE OF ACTION 9. This is an action for compensatory and punitive damages against Of?cer Schauder for violation of plaintiff?s constitutional and civil rights, by endangering her welfare as a minor, and by procuring, encouraging, inducing, soliciting and grooming her, as a minor, for sexual relations. Case Document 1 Filed 10/29/09 Page 3 of 10 PagelD: 3 Plaintiff also asserts claims for compensatory and punitive damages against the Department, Chief Gallagher and John Does 1-2.0, for implementing, maintaining and tolerating policies, practices and customs which resulted in the illegal actions of Officer Schauder and proximately caused plaintiff?s injuries as heretofore alleged. The actions of the defendants are in Violation of 42 U.S.C. 1983 and the Constitution of the United States of America. GENERAL ALLEGATIONS 10. In the summer of 2007, Officer Schander, while on patrol and acting within the scope of his employment, encountered the then seventeen~year old plaintiff and several of her friends and engaged plaintiff in conversation. 11. Following that meeting, using his mantle of authority and his position of trust and control over the minor plaintiff, through a careful process of seduction known in this context as ?grooming,? Officer Schauder befriended the plaintiff for the sole purpose of soliciting, recruiting and procuring the plaintiff, then a minor, for sexual relations. 12. In so doing, Officer Schauder engaged in a course of conduct which violated state, municipal and departmental rules, regulations, guidelines and orders, and in the course of his . employment, acting under color of state law, he willfully, intentionally, and knowingly deprived plaintiff of her rights, privileges and immunities of the laws of the United States of America including 42 U.S.C. 1983, to wit: a) While in the course of his employment, Officer Schander solicited and encouraged the minor plaintiff to telephone and/or text message his phone numerous times on a daily basis. b) While on~dnty, on multiple occasions Officer Schauder invited plaintiff to park her car next to his squad car where he engaged plaintiff in conversations dealing with plaintiff's family problems. In the course of these discussions, Officer Schauder learned that plaintiff?s parents Case Document 1 Filed 10/29/09 Page 4 of 10 PagelD: 4 were going through a divorce and, as a result, plaintiff suffered from anxiety, sadness and feelings of abandonment. o) By spending time talking and listening to the plaintiff, Officer Schauder observed her overwrought, vulnerable state of mind. With full knowledge of plaintiff?s emotional frailty, under the guise of providing emotional guidance and support, Of?cer Schauder cultivated plaintiff?s trust and affection through the ?grooming? process. (1) In the Spring of 2008, under the cloak of his employer?s authority, Of?cer Schauder further exploited the plaintiff by inviting her to sit with him in his squad car while stationed on duty. On many occasions, while Officer Schauder was on duty, plaintiff spent hours parked alone with him in secluded, wooded locations in the Township. Officer Schauder also drove his squad car to plaintiff?s home while her parents were away and spent considerable time conversing with plaintiff while parked in her driveway. e) Between March 2008 and May 16, 2008, while plaintiff was still a minor, Officer Schauder repeatedly lured plaintiff to his squad car on evenings when he was on~duty. There, Officer Schauder engaged in inappropriate contact with plaintiff including hugging, kissing and fondling plaintiff breasts and genital area through her clothing. Officer Schauder also allowed plaintiff to fondle his genitals through his clothing. f) In April of 2008, in furtherance of his ongoing scheme of seduction, Officer Schauder initiated a discussion with plaintiff about sexual intercourse with him after she turned eighteen years of age on May 16, 2008. Following that discussion, Officer Schauder and plaintiff began making plans for a sexual rendezvous after her birthday. Case Document 1 Filed 10/29/09 Page 5 of 10 PagelD: 5 g) On or about the evening of April 22, 2008, Of?cer Schauder drove his squad car to a house party where plaintiff was a guest. He picked her up from the party and she spent several hours with him in his car. Thereafter he returned. her to the party. h) Again, on or about May 8, 2008, at Of?cer Schauder?s invitation, plaintiff ran away from her horne and spent the night with him in his squad car. i) On many evenings from March 2008 through May 31, 2008, Of?cer Schauder parked for hours with plaintiff in his squad car in clandestine locations throughout the Township including the YMCA parking lot, Whippany Park High School parking lot, Airport Road, Bee Meadow Pool and other secluded areas. 13. As a result of months of careful seduction, Of?cer Schauder was able to gradually lessen plaintiff inhibitions resulting in the escalation of sexual contact with the plaintiff. 14. On May 31, 2008, Of?cer Schauder invited the now eighteen year old plaintiff to his marital residence while his wife and children were away. Of?cer Schauder purchased a thirty-pack of beer which he and plaintiff consumed during a weekend which plaintiff spent at Of?cer Schauder?s home engaging in sexual relations with him. 15. Following that weekend encounter, from June 7, 2007, through July 1, 2008, Of?cer Schauder engaged in sexual relations with plaintiff on dozens of occasions in his hozne, in plaintiff parents? home, and while onwduty in secluded locations throughout the Township both inside and on top of his squad car. 16. During that time, on many nights plaintiff would sneak out of her parent?s house to be with Of?cer Schauder while he was on?duty. On many of those occasions, plaintiff drove to Of?cer Schauder?s location after having consumed alcohol, and in a visibly intoxicated state. Although Case Document 1 Filed 10/29/09 Page 6 of 10 PagelD: 6 Of?cer Schauder was aware that the undenaged plaintiff was operating her motor vehicle while intoxicated, he did nothing to dissuade her conduct. In or about July 2008, Officer Schauder?s wife discovered his liaison with plaintiff. As a result, Officer Schauder was forced to end the relationship. 18. Upon information and belief, Of?cer Schauderis conduct with the plaintiff was open, visible and notorious to members of the Department including Chief Gallagher, who individually and in their professional capacities had personal knowledge of Officer Schauder?s sordid predatory conduct, which he boasted about to his fellow officers. 19. Despite such knowledge, these individuals negligently and/or knowingly failed to report Officer Schauder?s sexual misconduct and, acting under color of state law, concealed, covered? up and camou?aged Of?cer Schauder?s actions thereby aiding and abetting his lascivious activities. 20. Further, on or about July 14, 2009, plaintiff filed a Complaint Against Personnel against Officer Schauder with the Department, and submitted to an interview by the Department?s Internal Affairs Division. Upon information and belief, to date, the Department has taken no disciplinary action against Officer Schauder. FIRST COUNT (Against Officer Scha'uder) 42 1983 21. Plaintiff repeats the allegations contained in paragraphs l~20 inclusive as if set forth fully herein. 22. Officer Schauder, acting under color of state law, willfully, intentionally, knowingly deprived plaintiff of her rights, privileges, and immunities secured by the Constitution and the laws of: the United States of America, including the Fourth and Fourteen Amendments by using his mantle of Case Document 1 Filed 10/29/09 Page 7 of 10 PagelD: 7 authority, trust, and control as a police officer and under the guise of providing emotional guidance and support for the minor plaintiff, luring, enticing, procuring, soliciting and grooming her for sexual relations and needlessly and unreasonably subjecting her to sexual harassment. and sexual abuse. 23. The aforesaid actions are in violation of 42 U.S.C.. 1983 and the Constitution and laws of the United States of America. SECOND COUNT (Against the Township, the Police Department, Police Chief Gallagher and John Does 1~20) 42 U.S.C. 1983 24. Plaintiff repeats the allegations of paragraphs 1-23 inclusive as set forth fully herein. 25. Defendants, acting under color of state law, willfully, intentionally, knowingly and concertedly deprived plaintiff of her rights, privileges and immunities secured by the Constitution and the laws of the United States of America, including the Fourth and Fourteenth Amendments by the following actions; a) Implementing, maintaining, and tolerating policies, practices and customs which resulted in Officer Schauder?s illegal actions and proximately caused plaintiff?s injuries as heretofore alleged; b) Prior to the employment of Of?cer Schauder or to the assignment of duties whereby it was foreseeable that Officer Schauder would be required to interact with female members of the public, defendants failed to take reasonable steps to ascertain whether Of?cer Schauder was emotionally capable of performing such duties and did not have a propensity towards sexual harassment of females he was likely to encounter nor did defendants administer well?known and standard tests to ascertain Of?cer Schauder?s personality; Case Document 1 Filed 10/29/09 Page 8 of 10 PagelD: 8 c) Defendants grossly failed to train Of?cer Schauder as a police officer in the fundamental law of police procedures and protocol in dealing with minor female members of the pubhc; d) Prior to 2007, the defendants permitted, encouraged, tolerated and rati?ed a pattern and practice of unreasonable and illegal behavior by its police of?cers, including Of?cer Schauder, who routinely harassed and engaged in sexual relations with female members of the public who they encountered in their roles as police of?cers for the Township; e) Prior to 2007, the defendants failed to discipline or prosecute or in any manner deal with known incidents of wrongful behavior by its police of?cers, including Of?cer Schauder, involving the sexual harassment of female members of the public whom they encountered in their role as police of?cer; f) Prior to 2007, the defendants refused to and/or failed to investigate complaints of sexual harassment against its police of?cers, including Officer Schauder, by female members of the public whom they encountered. g) By means of both action or inaction and cover?up of such wrongful actions by its police of?cers, including Of?cer Schauder, with regard to the sexual harassment of female members of the public, the defendants encouraged its police of?cers, including Officer Schauder, to believe that this type of sexual impropriety was permissible. 24. The actions of the defendants and their emissions and systematic failures are customs and policies caused police of?cers, including Of?cer Schauder, to believe that sexual harassment was within their discretion and that complaints of sexual harassment would not be honestly or properly investigated, with the foreseeable result that of?cers, including Of?cer Schauder, would be likely to sexually harass female members of the public. Case Document 1 Filed 10/29/09 Page 9 of 10 PagelD: 9 25. As a direct and proximate result of the aforesaid acts, omissions, policies and customs, the defendant, Officer Schauder, solicited, lured, procured and groomed plaintiff for sexual relations on repeated occasions from on or about June 2007, through May 31, 2008, which culminated in improper sexual relations between Officer Schauder and the plaintiff on dozen of occasions between May 31, 2008, and July 2008. 26. Officer Schauder?s wrongful conduct was visible, open and notorious to the defendants who negligently and/or knowingly failed to report Officer Schauder?s sexual misconduct and, acting under color of state of law, concealed, covered-up and obfuscated Officer Schauder?s actions thereby aiding and abetting his lascivions activities. 27. Further, on or about July 14, 2009, plaintiff filed a Complaint Against personnel against Officer Schauder with the Department, and submitted to an interview by the Department?s Internal Affairs Division. Upon information and belief to date, the Department has taken no disciplinary action against Officer Schauder. (Against all Defendants) Punitive Damages 28. Plaintiff repeats the allegations of paragraphs 1-27 inclusive as if set forth herein. 29. The aforesaid actions of the defendants were willful, wanton and reckless and so as to permit a jury to consider the awarding of punitive damages and/or exemplary damages to the plaintiff. PRAYER FOR RELIEF 30. Plaintiff repeats the allegations of paragraphs 1?29 inclusive as if set forth fully herein. 31. Plaintiff demands judgment against all defendants and each of them, jointly and. severally as follows: Case Document 1 Filed 10/29/09 Page 10 of 10 PagelD: 10 a) Where applicable, plaintiff demands judgment for compensatory damages. b) Where applicable. plaintiff demands judgment for punitive damages and exemplary damages, and any and all other damages allowed by law. (2) Plaintiff demands judgment for all equitable and other relief as the Court deems just and proper. d) Plaintiff demands judgment of attorney?s fees with interest and costs of suit. DEMAND FOR JURY TRIAL Plaintiff hereby demands trial by jury pursuant to the Federal Rules of Civil Procedure 3813 on all issues so triable herein. LACORTE, BUNDY, VARADY KINSELLA Robert F. Varadv, Esq. By: Robert F. Varady, Esq. Date: October 29, 2009 10 Case Document 1-1 Filed 10/29/09 Page 1 of 1 PageID: 11 LA CORTE, BUNDY, VARADY KINSELLA ATTORNEYS AT LAW 989 BONNEL COURT UNION. NEW JERSEY 07083 (908) 810-0500 CORTE (1911-19?8) FAX: (908) 81043513 ggtgiciglao TRIAL ATTORNEY ROBERT F. VARADY J. KINSELLA E~Mail: EN REPLY REFER TO FILE NO. Ric HARD M. BROC KWAY October 29, 2009 Clerk of United States District Court District of New Jersey ML. King, Jr. Federal Building US. Courthouse 50 Walnut Street Newark, NJ 07102 Re: Jane Doe V. Hanover Township, et. a1. Dear Sir or Madam: Enclosed please find a copy of plaintiff Complaint and Jury Demand in the above captioned matter. The Complaint is being electronically ?led and the fee of $3 50.00 was paid electronically by this ?rm.?s credit card. Thank you for your cooperation with regard to the above matter. Very truly yours, LA CORTE, KINSELLA By: -- Robert F. arady, Esq. Filed Electronically Case 2:09-cv-05532-PGS-ES Document 5 Filed 12/14/09 Page 1 of 8 PageID: 28 METHFESSEL & WERBEL, ESQS. 3 Ethel Road, Suite 300 PO Box 3012 Edison, New Jersey 08818 (732) 248-4200 +1(732) 248-2355 mailbox@methwerb.com Attorneys for: John Schauder as to the First and Second Counts of the Complaint Our File No. 71975 ELH UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY JANE DOE (A FICTITIOUS NAME) Plaintiff, CIVIL ACTION NO.: 2:09-cv-05532-PGS-ES V. HANOVER TOWNSHIP, HANOVER TOWNSHIP POLICE DEPARTMENT, JOHN SCHAUDER, INDIVIDUALLY, AND IN HIS OFFICIAL CAPACITY AS A POLICE OFFICER OF THE HANOVER TOWNSHIP POLICE DEPARTMENT, STEPHEN W. GALLAGHER, INDIVIDALLY, AND IN HIS OFFICIAL CAPACITY AS A CHIEF OF POLICE OF THE HANOVER TOWNSHIP POLICE DEPARTMENT, JOHN DOES 1-20, A FICTITIOUS NAME FOR PRESENTLY UNKNOWN AGENTS, MEMBERS, COMMISSIONERS, CHIEFS, REPRESENTATIVES, OR EMPLOYEES OF THE HANOVER TOWNSHIP POLICE DEPARTMENT, INDIVIDUALLY, AND IN THEIR OFFICIAL CAPACITIES. ANSWER AS TO THE FIRST AND SECOND COUNTS OF THE COMPLAINT & CROSSCLAIMS Defendants. Defendant John Schauder, by way of Answer as to the First and Second Counts of the Complaint to the Complaint, says: Case 2:09-cv-05532-PGS-ES Document 5 Filed 12/14/09 Page 2 of 8 PageID: 29 JURISDICTION & VENUE 1. Admitted. 2. Admitted. PARTIES 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Neither admitted nor denied (fictitious parties). NATURE OF ACTION 9. Admitted that the Complaint so describes the action; otherwise denied. GENERAL ALLEGATIONS 10. Admitted insofar that the plaintiff met and conversed while Officer Schauder was on patrol in the Summer 2007; otherwise denied. 11. Denied. 12. Denied. 13. Admitted insofar as this defendant and the plaintiff engaged in a consensual sexual relationship; otherwise denied. 14. Admitted insofar as this defendant and the plaintiff engaged in a consensual sexual relationship; otherwise denied. Case 2:09-cv-05532-PGS-ES Document 5 Filed 12/14/09 Page 3 of 8 PageID: 30 15. Admitted insofar as this defendant and the plaintiff engaged in a consensual sexual relationship; otherwise denied. 16. Denied. 17. Admitted that Officer Schauder ended the relationship; otherwise denied. 18. Denied. 19. Denied. 20. Admitted insofar as the plaintiff apparently filed an internal affairs complaint; otherwise denied. FIRST COUNT 21. See above responses. 22. Denied. 23. Denied. SECOND COUNT 24. See above responses. 25. Denied. 24 (misnumbered). Denied. 25. Denied. 26. Denied. 27. Admitted insofar as the plaintiff apparently filed an internal affairs Complaint; otherwise denied. THIRD COUNT 28. See above responses. Case 2:09-cv-05532-PGS-ES Document 5 Filed 12/14/09 Page 4 of 8 PageID: 31 29. Denied. PRAYER FOR RELIEF 30. See above responses. 31. Denied. WHEREFORE defendant John Schauder demands judgment dismissing the Complaint with prejudice and awarding fees, costs and such other relief as the Court may deem just and equitable. FIRST SEPARATE DEFENSE The Complaint fails to state a claim upon which relief may be granted. SECOND SEPARATE DEFENSE Defendant was not guilty of any negligence, wrongdoing, breach of duty, or misconduct that was the proximate or producing cause of any injuries or damages alleged by plaintiff. SIXTH SEPARATE DEFENSE Any injuries and damages were caused by and arose out of risks of which plaintiff had full knowledge and which plaintiff assumed. SEVENTH SEPARATE DEFENSE Any and all injuries and damages were caused solely by the negligence of the plaintiff. EIGHTH SEPARATE DEFENSE Any and all injuries and damages were caused solely by the intentional behavior of the plaintiff. Case 2:09-cv-05532-PGS-ES Document 5 Filed 12/14/09 Page 5 of 8 PageID: 32 TWELFTH SEPARATE DEFENSE Plaintiff has not been deprived of any right, privilege, or immunity created or recognized by the United States Constitution, the New Jersey Constitution, any statute, or any law. THIRTEENTH SEPARATE DEFENSE The conduct of this defendant of which plaintiff complains did not occur within the scope of his work as a police officer, therefore it was not action taken under color of law. TWENTY-EIGHTH SEPARATE DEFENSE Defendant at all times acted reasonably, in good faith, and in accordance with all applicable laws of the United States, State of New Jersey, and local ordinances. THIRTY-FIRST SEPARATE DEFENSE All of the acts of defendant which were taken under color of law were performed in good faith and defendant is therefore entitled to qualified immunity. THIRTY-THIRD SEPARATE DEFENSE Defendant did not engage in a conspiracy against plaintiff and did not have a custom, plan or practice that violated plaintiff’s rights. THIRTY-FOURTH SEPARATE DEFENSE Case 2:09-cv-05532-PGS-ES Document 5 Filed 12/14/09 Page 6 of 8 PageID: 33 Plaintiff is not entitled to an award of punitive damages. THIRTY-SEVENTH SEPARATE DEFENSE Plaintiff is not entitled to an award of interest against defendant. THIRTY-EIGHTH SEPARATE DEFENSE Plaintiff is not entitled to an award of counsel fees against defendant. FORTY-EIGHTH SEPARATE DEFENSE To the extent not inconsistent with anything pleaded herein, this defendant joins in the affirmative defenses asserted by the codefendants. FORTY-NINTH SEPARATE DEFENSE Defendant reserves its right to assert such other affirmative defenses as continuing investigation and discovery may indicate. ANSWER TO ALL CROSSCLAIMS Defendant John Schauder as to the First and Second Counts of the Complaint, by way of answer to any and all crossclaims which have been or will be interposed, denies each and every allegation of said crossclaims. CROSSCLAIM FOR INDEMNIFICATION While denying any liability, John Schauder as to the First and Second Counts of the Complaint asserts that to the extent plaintiff’s alleged injuries and damages were the proximate result of actions taken Case 2:09-cv-05532-PGS-ES Document 5 Filed 12/14/09 Page 7 of 8 PageID: 34 in furtherance of his official duties, he is entitled to indemnification from Hanover Township pursuant to N.J.S.A. 40A:14-155. JURY DEMAND The defendant hereby demands trial by a jury as to all issues. METHFESSEL & WERBEL, ESQS. Attorneys for John Schauder as to the First and Second Counts of the Complaint DATED: December 14, 2009 By:________________________________ Eric L. Harrison Case 2:09-cv-05532-PGS-ES Document 5 Filed 12/14/09 Page 8 of 8 PageID: 35 Our File No. 71975 CERTIFICATE OF MAILING The undersigned hereby certifies as follows: l. I am employed by the law firm of Methfessel & Werbel. 2. On December 9, 2009 the undersigned prepared and forwarded copies of the within correspondence to the following parties: Via E-Filing Clerk, United States District Court Clarkson S. Fisher Federal Building 402 E. State Street Trenton, NJ 08608 VIA FAX (908) 810-0513 Robert F. Varady, Esq. LaCorte, Bundy & Varady, & Kinsella, Esqs. 989 Bonnel Court Union, NJ 07083 Attorneys for: Jane Doe 3. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. ____________________________________ Eric L. Harrison Case 2:09-cv-05532-PGS-ES Document 5-1 Filed 12/14/09 Page 1 of 2 PageID: 36 METHFESSEL & WERBEL A Professional Corporation JOEL N. WERBEL> JOHN METHFESSEL, JR.> EDWARD L. THORNTON*> DONALD L. CROWLEY*+ FREDRIC PAUL GALLIN*+^ STEPHEN R. KATZMAN# WILLIAM S.BLOOM>* ERIC L. HARRISON*+ MATTHEW A. WERBEL> Counsel Associates LORI BROWN STERNBACK*+ MARC DEMBLING*+ PAUL J. ENDLER JR.> GERALD KAPLAN+ JARED P. KINGSLEY*+ STEVEN A. KLUXEN^ JOHN R. KNODEL*+ CHARLES T. MCCOOK, JR. *> MARTIN R. MCGOWAN, JR.> EDWARD D DEMBLING> MICHAEL R. EATROFF> TIMOTHY J. FONSECA+ SCOTT V. HECK+ MAURICE JEFFERSON> FRANK J. KEENAN+^ JENNIFER M. HERRMANN^= RAINA M. JOHNSON^ LESLIE A. KOCH+ ALLISON M. KOENKE> DANIELLE M. LOZITO+ ANDRES Y. MEJER+ KEITH J. MURPHY+ JEFFREY D. NOONAN> CAROLINE PYRZ^ MATTHEW L. RACHMIEL> WILLIAM J. RADA+ CHARLES P. SAVOTH, III> AMANDA J. SCHMESSER^ MICHELLE M. SCHOTT> GINA M. STANZIALE> ADAM S. WEISS< Of Counsel JOHN METHFESSEL, SR.> December 14, 2009 VIA ELECTRONIC FILING Clerk, United States District Court Clarkson S. Fisher Federal Building 402 E. State Street Trenton, NJ 08608 RE: DOE, JANE VS. HANOVER TOWNSHIP, ET AL. Our File No. : 71975 ELH * Certified by the Supreme Court of New Jersey as a Civil Trial Attorney +Member of NY & NJ Bar ^ Member of PA & NJ Bar >Member of NJ Bar only # Member of NJ & LA. Bar %Member of MI Bar