Latest Complaint filed against Chief, Padilla, Garcia & City

Well when I started to post this it was the latest complaint. Now I find out there is a 20th officer who has filed against Zisa - this is just beyond ridiculous


LAW OFFICES OF JOHN J. ZIDZIUNAS, LLC
JOHN J. ZIDZIUNAS, ESQUIRE
33 Plymouth Street, Suite 202A
Montclair, NJ 07042
973-509-8500
Attorneys for Plaintiffs
MARK B. FROST & ASSOCIATES
MARK B. FROST, ESQUIRE
7 North Columbus Boulevard, 2nd Floor
Philadelphia, PA 19106
215-351-3333
Attorneys for Plaintiffs
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
LAURA CAMPOS, RICHARD
MELBER,
Plaintiffs,
vs.
CHIEF C. KENNETH ZISA,
CAPTAIN TOMAS PADILLA,
CAPTAIN DANILO GARCIA, and
CITY OF HACKENSACK,
Defendants.
Civil Action No.:
COMPLAINT AND JURY DEMAND
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INTRODUCTION
1. Each of the Plaintiffs in the within action were retaliated against by being detrimentally
transferred for supporting candidates opposed to Defendant Chief Zisa and/or failing to
contribute to various public and PBA elections. Furthermore, Plaintiff Campos was
sexually harassed by Defendant Garcia with the knowledge of Chief Zisa and, under
threat of retaliation, was forced by both Zisa and Garcia to change an official report.
JURISDICTION
2. This action is brought pursuant to 42 U.S.C. §1983 and the First and Fourteenth
Amendments of the United States Constitution. Jurisdiction is founded on 28 U.S.C.
§1331 and 1343(3) and the aforementioned statutory and constitutional provisions.
3. Jurisdiction lies over state law claims based on the principles of supplemental
jurisdiction, as codified at 28 U.S.C §1367.
4. The amount in controversy exclusive of interest and costs exceeds the sum of one
hundred thousand Dollars ($100,000).
VENUE
5. All the claims herein arose within the jurisdiction of the United States District Court for
the District of New Jersey and involve Defendants who reside within the jurisdictional
limits. Venue is accordingly invoked pursuant to the dictates of 28 U.S.C. §1391(b) and
(c).
PARTIES
6. Plaintiff Laura Campos is a citizen of the State of New Jersey residing at 7 Madison
Avenue, Midland Park, New Jersey.
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7. Plaintiff Richard Melber is a citizen of the State of New Jersey residing at 112 Davis
Drive, River Edge, New Jersey.
8. Defendant Chief C. Kenneth Zisa is, and was at all times material hereto, the Chief of
Police of the Hackensack Police Department, located at 225 State Street, Hackensack, NJ
07601.
9. Defendant Tomas Padilla is, and was at all times material hereto, an Officer with the
Hackensack Police Department, located at 225 State Street, Hackensack, NJ 07601.
Defendant Padilla is a Captain with supervisory duties and authority to institute
disciplinary action.
10. Defendant Captain Danilo Garcia is, and was at all times material hereto, an Officer with
the Hackensack Police Department, located at 225 State Street, Hackensack, NJ 07601.
LAURA CAMPOS
SEXUAL HARRASMENT
11. Plaintiff has been a police officer in the City of Hackensack since January 2002.
12. Since Plaintiff has been a police officer at Hackensack Police Department, she has been
subjected to sexual harassment by Captain Danilo Garcia beginning in the fall of 2002
and continuing to 2010.
13. In the fall of 2002, Captain Garcia was a desk lieutenant and Plaintiff was a patrol officer.
Furthermore, Defendant was Plaintiff’s supervisor.
14. The desk at headquarters where Lieutenant Garcia was stationed contained a large stash
of pornographic magazines
15. Defendant Garcia stated to Ms. Campos, while looking at the magazine, commented to
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the Plaintiff if the woman’s ass was real. Garcia further commented by stating to the
Plaintiff that “your ass is real.”
16. On other occasions while looking at pornographic magazines, Garcia made a number of
sexual remarks to Campos related to Plaintiff’s vagina and pubic hair.
17. Campos, still under probation since she had only been in the department for less than a
year, did not make any complaints at that time for fear of losing her job and/or retaliation.
18. During the year of 2003, Garcia repeatedly spoke to Ms. Campos in a sexual manner,
always making comments about how good she looked in a uniform as well as stating how
good her “ass” looked.
19. From February 6, 2004 to July 7, 2004, the Plaintiff was temporarily assigned to the
narcotics division under Captain Arthur Mento. While on that detail Garcia stated to the
Plaintiff “Nice JF look.” He further stated, “Gotta look like a crackhead, right?”
20. Plaintiff did not know exactly what “JF” stood for and was later told that JF stood for
“just fucked.”
21. At that time Plaintiff complained to Captain Mento about the incident. No action was
taken against Defendant Garcia who was a Captain at that time.
22. After the temporary assignment Garcia continued with his sexual harassment and made a
number of advances in 2004.
23. In May of 2005 Plaintiff spoke with Captain Garcia about her schedule since she was
planning on getting married to patrol officer Brian Corcoran, her fiancé at the time.
Garcia had previously separated the two of them by changing her schedule so she would
not be able to see him while at work and so Garcia could make more sexual advances to
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the Plaintiff which Plaintiff rejected. Plaintiff requested that her schedule be changed and
in doing so, Defendant stated to the Plaintiff “how dare you? I run the fucking division
and I will schedule officers as I see fit.” Garcia further stated that Plaintiff is illiterate,
and commented that she should write in English and not in “spicklish.” Defendant
Garcia stated that he had the Chief’s full support in everything as it relates to her. He
further stated that he was having every tour commander and sergeant review her reports.
24. In the summer of 2005 she was at a local bar in Hackensack known as Lazy Lanigans. At
the time Garcia wanted to buy Plaintiff a drink and she refused. At the time there were
numerous officers from the department at the bar. When Campos rejected the drink
Garcia said to her “you know what Campos needs is a real man to fuck her.” Her fiancé
was in the vicinity and got into an argument over the comment that resulted in a shoving
match between Corcoran and Garcia. After the incident Plaintiff was assigned to a
walking post which was used as punishment in the City of Hackensack.
25. In September 2005, Plaintiff was assigned a dispatch position. Garcia entered the radio
room and put his hands on her left shoulder and started to rub them and implied in a
sarcastic tone that Plaintiff had “slashed tires on his truck.” After this conversation,
Plaintiff was assigned to a walking post even though he knew that she did not slash his
tires.
26. Later that fall, Plaintiff was involved in an arrest that required her to work overtime and
she sought overtime payment. Captain Garcia was the individual at that time who had
authority to approve the overtime. He refused to do so and started berating the Plaintiff.
27. A few days later Plaintiff contacted Chief Zisa and in front of the Chief and two deputies,
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stated that she had been subjected to sexual harassment, sexual advances, humiliation and
other abuse from Captain Danilo Garcia.
28. Despite these complaints, no action was taken against Captain Garcia.
29. In 2006 Plaintiff was out for a back injury and gall bladder surgery from February 13th to
June 30th. During that time period, Defendant Garcia tried to hurt Plaintiff’s career by
forcing her to come back to work before she was physically able to do so under the threat
of retaliation that Plaintiff would be forced to take a 40% disability pension.
30. Fearing that she would be put out on pension and further retaliation would take place,
Plaintiff came back to work in the beginning of July of 2006.
31. On December 6, 2006 at a Christmas party, Garcia once again made sexual advances
toward the Plaintiff and stated to her “why aren’t you shaking your nice ass?”
32. In August 2007 Plaintiff was once again at Lazy Lanigans with a friend. Garcia came to
the bar and stated to the Plaintiff, “I hear you are not with Brian Corcoran anymore. Are
you ready for some of this?” as he grabbed his crotch.
33. In December 2007 at another holiday party, Defendant asked the Plaintiff where
everyone was going after the party and Plaintiff stated that she was going home.
Defendant put his hand on her back and said “don’t be like that.” After that incident
Plaintiff was transferred to walking.
34. In May 2008 Plaintiff was working patrol when she dropped off reports when Garcia saw
her in the radio room and stated to her that he heard her ass was looking good at the HCop.
party. Plaintiff stated to Garcia that she had to leave and would not converse with
Plaintiff.
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35. As a result of Plaintiff refusing to speak with Defendant, on July 17, 2008, Garcia took
Plaintiff out of the AR-15 response team for which plaintiff was qualified to participate.
36. Plaintiff was told by Lieutenant Pierce that Defendant Garcia has a personal thing for you
and won’t give up.
37. At the October 8, 2008 Beefsteak dinner fundraiser for Padilla Garcia again tried to buy
the Plaintiff a drink and she refused. Defendant continued to try to buy Plaintiff drinks at
the beefsteak dinner and told her that her “ass looks really good in those jeans and those
fuck-me boots.”
38. On March 17, 2010 Plaintiff was traveling north on Railroad Avenue in an assigned radio
car.
39. As she got closer to the intersection of Railroad and Berry she noticed Garcia driving an
unmarked car. He then followed her into the Dunkin’ Donuts on Passaic Street.
40. Plaintiff thereafter bought doughnuts for the housing children and proceeded to her
assignment at 230 Central Avenue. Garcia continued to follow the Plaintiff.
41. Soon thereafter Plaintiff parked her car on Central Avenue and Garcia drove by and
continued west on Central Avenue.
42. These acts were done to the Plaintiff to intimidate the Plaintiff for her past rejections of
Defendant’s sexual harassment.
PBA ELECTIONS
43. In June of 2008, a Policemen’s Benevolent Association (PBA) delegate election was held
inside the locker room of the Hackensack Police Department (HPD).
44. The two candidates running for PBA delegate were Police Officer Joseph Inglima and
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Detective Tina Clouse.
45. Prior to the election, Chief Zisa and Captain Padilla made it openly known to all HPD
officers that he desired Clouse to win the election and they must vote to Clouse to
demonstrate their loyalty to them.
46. Zisa made it apparent that failure to vote for Clouse would result in direct retaliation in
the workplace but not limited to undesirable positions, assignments that were considered
disciplinary assignments, like foot patrol, or failure to promote others who were up for
promotion on eligibility lists.
47. To achieve the election of Clouse, Zisa instructed Officer Cinque to wear a sign on his
back that read “Vote for Clouse” prior to the election. The sign was observed by nearly
all HPD members prior to voting.
48. Zisa further instructed Sergeant Jamie Barrios to stand in front of the ballot box and
demand that all officers show him the written votes. Barrios took note on a newspaper
recording the names of those who would not show their vote.
49. On the day before the election Sergeant Trezza approached the Plaintiff and stated do the
right thing by voting for Clouse. He further stated if she did not vote for her that her
assignment could be changed.
50. Plaintiff was further told to vote in front of Barrios and show him her vote. Barrios
requested the Plaintiff to show him her vote.
51. Plaintiff went to a private area to vote for Inglima and did not show her vote to Barrios.
52. In July 2008, just weeks after the election, Plaintiff was transferred to Community
Resource Center and her hours were changed.
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53. Plaintiff was told by Captain Wright that the reason for the transfer was due to her failure
to support Clouse and that to take her assignment as punishment for her failure to support
Clouse.
54. The assignment was detrimental to the Plaintiff in that she has two children and her hours
were changed from 1:00PM to 9:00PM. This gave little time for Plaintiff to assist her
children with homework assignments and other activities. Prior to the transfer, Plaintiff
worked four days on four days off, and the four days on she was able to have coverage
for her children with the father of the children. Under this new schedule she was unable
to arrange for the necessary coverage of her children.
OFFICIAL MISCONDUCT
55. In the early part of 2004, Plaintiff responded to an alleged robbery and wrote a
subsequent report involving the then girlfriend of defendant Chief Zisa, Kathleen
Tiernan’s son, because he was a suspect in a robbery.
56. In writing her report, Plaintiff initially specified the name of the aforementioned
individual juvenile involved in the case. Under threat and fear of retaliation, plaintiff was
ordered by her superior officer, Captain Garcia, to change the report not to implicate
Tiernan’s son. Garcia further indicated to plaintiff that the order came from Chief Zisa.
57. Upon information and belief, Chief Zisa shredded reports relating to this matter knowing
that these reports could be used against him at a later date.
58. At that time, Plaintiff had already been subjected to numerous retaliatory acts and sexual
advances by Captain Garcia and, fearful of further retaliation to a walking assignment
and other retaliatory assignments, Plaintiff changed the report to remove Tiernan’s name
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from the report as a suspect.
CAMPAIGN DONATIONS
59. During Plaintiff’s career, Plaintiff has been threatened with retaliation if she did not
support Zisa’s candidacies for State Assembly and other elected offices and other
individuals that Defendant Chief Zisa supported, as well as for the candidacies of
Defendant Tomas Padilla for County Freeholder.
60. Plaintiff, at the time she was initially employed by the City of Hackensack, was a
registered Republican.
61. In 2005, she was requested to switch parties so she could support Zisa and his
candidacies and other individuals that he supported. Plaintiff throughout her career
contributed to Chief Zisa’s candidacies under fear of retaliation.
62. In the fall of 2008 she was requested by Sergeant Trezza to purchase a ticket for a
Beefsteak dinner to support Captain Padilla who was running for County Freeholder.
63. She was requested to not only purchase the ticket, but also donate $125.00 to his
campaign.
64. Plaintiff initially refused to donate $125.00 but did purchase a ticket for $65.000. She
was told by Officer Corcoran that if she did not purchase the ticket that she would be
retaliated against.
65. Since Plaintiff had already been retaliated against for her failure to support Tina Clouse
in the PBA election for state delegate, fearful of further retaliation, Plaintiff contributed
the monies to Defendant Padilla.
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RICHARD MELBER
66. Plaintiff Richard Melber is a police officer in the City of Hackensack and was hired in
November 1987.
67. Plaintiff was a partner with Joseph Inglima in the traffic division from 2001 through
2006.
68. In 2006 Plaintiff was transferred from the traffic division to the patrol division where he
remained until August 2008.
69. In May 2008 Plaintiff publicly supported Joseph Inglima and nominated him to become
the PBA delegation.
70. It is well known in the Hackensack Police Department that Plaintiff Melber not only
nominated Inglima for State Delegate, but also supported him openly for this position.
71. In mid-June 2008 the PBA State Delegate election was held.
72. The two candidates running for PBA delegate were Police Officer Joseph Inglima
(Inglima) and Detective Tina Clouse (Clouse).
73. Prior to the election, Chief Zisa made it openly known to all HPD officers that he desired
Clouse to win the election, and that they must vote for Clouse to demonstrate their loyalty
to him.
74. Zisa made it apparent that failure to vote for Clouse would result in direct retaliation in
the workplace.
75. To achieve this end, Zisa instructed Captain Dennis Cinque to wear on a sign on his back
that read AVote for Clouse, prior to the election.
76. Chief Zisa also directed a “Vote for Clouse” sign be affixed to the City vehicle that
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patrols the police department parking lot.
77. These signs were observed by nearly all HPD members prior to voting, including
Plaintiff.
78. Moreover, Zisa instructed Sergeant Jaime Barrios to stand in front of the ballot box and
demand that all officers show him their written votes.
79. Plaintiff was told in advance of the election that failing to show Barrios his vote was
considered a “no vote” for Clouse, and disloyalty to Zisa.
80. Barrios took notes on a newspaper recording the names of those who would not show
their vote.
81. Plaintiff made it openly known to his superiors and Zisa that he would not vote for
Clouse and that he supported Inglima.
82. Inglima ultimately won the PBA election.
83. For not supporting the Chief and Clouse, Plaintiff was retaliated against by Chief Zisa
and beginning in August of 2008 was transferred from patrol to a walking post at a
Federal housing area for a period of almost one (1) year. This area was known as a high
crime and high drug area. Plaintiff was ordered to walk in this area alone.
84. This assignment was made by Chief Zisa and was for the purpose of retaliating against
the Plaintiff for his support of Inglima at the PBA election.
85. Prior to the transfer, Plaintiff was making approximately $10,000.00 per year in overtime.
86. As a result of the transfer, Plaintiff received no overtime work.
87. Not only was the transfer to the housing authority a retaliatory punishment, but also the
hours that Plaintiff had to work were also retaliatory in that he had to work every
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weekend as well as working from 5:00PM to 1:00AM, which gave him very little time to
spend with his family.
88. Prior to the 2008 PBA election and subsequent thereto, the Plaintiff has been asked by
various police officers in the Hackensack Police Department to donate monies to the
campaigns of Zisa as well as to the campaigns of Padilla.
89. Contributions were made by the Plaintiff in fear of retaliatory assignments for supporting
any of these candidacies.
COUNT I
PLAINTIFF LAURA CAMPOS V. CHIEF KEN ZISA AND TOMAS PADILLA
42 U.S.C. §1983
(FIRST AMENDMENT VIOLATIONS)
90. Plaintiff adopts and incorporates the allegations in paragraphs 1-89 as though each were
individually stated herein at length.
91. Defendants violated the provisions of 42 U.S.C. §1983 in that Defendants, acting under
color of state law, deprived Plaintiff of the privileges and immunities secured to her by
the First and Fourteenth Amendments of the United States Constitution and, in particular,
her right to hold employment without infringement of her First Amendment right to
freedom of speech and association.
92. Defendant Chief Zisa willfully and recklessly transferred, demoted, disciplined and
threatened Plaintiff with discipline for her refusal to support Chief Zisa’s candidacy and
those he supported including Padilla and Clouse in order to deny Plaintiff her First
Amendment right to free speech and association.
93. Defendant Padilla, acting through other police officers, threatened Plaintiff with
retaliation if she did not support his candidacy for public office.
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94. Defendants’ actions were to penalize and retaliate against Plaintiff for her exercise of
fundamental First Amendment rights.
WHEREFORE, Plaintiffs respectfully request this Honorable Court:
i. Enter a declaratory judgment that Defendants’ retaliatory acts complained of
herein have violated and continue to violate the rights of Plaintiff as secured by
the United States Constitution;
ii. Enjoin Defendants from continuing said retaliatory practices;
iii. Award Plaintiffs compensatory damages including but not limited to: pain,
suffering, past economic loss, future economic loss, back pay, front pay, wage
increases, loss of life’s pleasures, loss of reputation, benefits, emotional distress
and other damages;
iv. Award reasonable costs and attorney’s fees;
v. Award punitive damages;
vi. Grant any other relief this Court deems just and proper under the circumstances.
COUNT II
PLAINTIFF RICHARD MELBER V. CHIEF KEN ZISA
42 U.S.C. §1983
(FIRST AMENDMENT VIOLATIONS)
95. Plaintiff adopts and incorporates the allegations in paragraphs 1-94 as though each were
individually stated herein at length.
96. Defendants violated the provisions of 42 U.S.C. §1983 in that Defendants, acting under
color of state law, deprived Plaintiff of the privileges and immunities secured to him by
the First and Fourteenth Amendments of the United States Constitution and, in particular,
his right to hold employment without infringement of his First Amendment right to
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freedom of speech and association.
97. Defendant Chief Zisa willfully and recklessly transferred, demoted, disciplined and
threatened Plaintiff with discipline for his refusal to support Chief Zisa’s candidacy and
those he supported including Padilla and Clouse in order to deny Plaintiff his First
Amendment right to free speech and association.
98. Defendant Padilla, acting through other police officers, threatened Plaintiff with
retaliation if he did not support his candidacy for public office.
99. Defendants’ actions were to penalize and retaliate against Plaintiff for his exercise of
fundamental First Amendment rights.
WHEREFORE, Plaintiff respectfully requests this Honorable Court:
i. Enter a declaratory judgment that Defendants’ retaliatory acts complained of
herein have violated and continue to violate the rights of Plaintiff as secured by
the United States Constitution;
ii. Enjoin Defendants from continuing said retaliatory practices;
iii. Award Plaintiffs compensatory damages including but not limited to: pain,
suffering, past economic loss, future economic loss, back pay, front pay, wage
increases, loss of life’s pleasures, loss of reputation, benefits, emotional distress
and other damages;
iv. Award reasonable costs and attorneys’ fees;
v. Award punitive damages;
vi. Grant any other relief this Court deems just and proper under the circumstances.
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COUNT III
PLAINTIFF CAMPOS V. CHIEF KENNETH ZISA,
TOMAS PADILLA, AND DANILO GARCIA
(COMMON LAW CONSPIRACY)
100. Plaintiff adopts and incorporates the allegations in paragraphs 1-99 as though each were
individually stated herein at length.
101. The Defendants named in this count conspired to violate Plaintiff’s First Amendment
rights including but not limited to freedom of speech and freedom of association, by
coercing Plaintiff, under threat of retaliation to financially and politically support the
candidacies of Defendants Zisa and Padilla and other candidates of Defendant Zisa’s
choosing including PBA elections.
102. Defendant Zisa conspired with Garcia so he could sexually harass the Plaintiff without
taking any action as well as so he could perform acts of official misconduct in having
Plaintiff change an official report involving Tiernan under threat of retaliation.
103. Further, Plaintiff has been required to retain an attorney to assist Plaintiff in asserting
Plaintiff’s claims and protecting Plaintiff’s rights.
WHEREFORE, Plaintiff respectfully requests this Honorable Court:
i. Enter a declaratory judgment that Defendants’ acts complained of herein have
violated and continue to violate the rights of Plaintiffs as secured by the United
States Constitution;
ii. Enjoin Defendant from continuing said practices;
iii. Award Plaintiffs compensatory damages including but not limited to: pain,
suffering, past economic loss, future economic loss, back pay, front pay, wage
increases, loss of life’s pleasures, loss of reputation, benefits, emotional distress
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and other damages;
iv. Award reasonable costs and attorney’s fees;
v. Award punitive damages;
vi. Grant any other relief this Court deems just and proper under the circumstances.
COUNT IV
PLAINTIFFS CAMPOS AND MELBER V. CITY OF HACKENSACK,
DEFENDANT ZISA AND DEFENDANT GARCIA
(VIOLATION OF 42 U.S.C. §1983)
104. Plaintiffs adopt and incorporate the allegations in paragraphs 1-103 as though each were
individually stated herein at length.
105. Defendant City of Hackensack developed and maintained a number of deficient policies
and/or customs which caused the deprivation of Plaintiff Campos and Melber’s
constitutional rights.
106. Defendant City of Hackensack’s policies and customs encouraged Defendant Zisa to
believe that he could violate the constitutional rights of Plaintiffs with impunity and with
the explicit or tacit approval of the Defendant City of Hackensack.
107. The deficient policies and practices allowed Chief Zisa to conspire with others including
Defendant Garcia to force Plaintiff Campos to change her report in the criminal
investigation of his then-girlfriend Tiernan’s son by threatening and intimidating
retaliation against the Plaintiff. Said acts were in violation of the law and constituted
official misconduct on the part of Defendants Zisa and Garcia.
WHEREFORE, Plaintiffs respectfully request this Honorable Court:
i. Enter a declaratory judgment that Defendant’s acts complained of herein have
violated and continue to violate the rights of Plaintiffs as secured by the United
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States Constitution;
ii. Enjoin Defendant from continuing said practices;
iii. Award Plaintiffs compensatory damages including but not limited to: pain,
suffering, past economic loss, future economic loss, back pay, front pay, wage
increases, loss of life’s pleasures, loss of reputation, benefits, emotional distress
and other damages;
iv. Award reasonable costs and attorney’s fees;
v. Award punitive damages;
vi. Grant any other relief this Court deems just and proper under the circumstances.
COUNT V
PLAINTIFF CAMPOS V. CHIEF KENNETH ZISA, CITY OF HACKENSACK
VIOLATION OF THE NEW JERSEY LAW AGAINST DISCRIMINATION
(N.J.S.A. 10:5-1 et seq. – SEXUAL DISCRIMINATION)
108. Plaintiff incorporates by reference the preceding allegations of paragraphs 1-107 of this
Complaint as though each were individually set forth herein at length.
109. Defendant’s actions aforesaid violate the New Jersey Law Against Discrimination
(“NJLAD”), N.J.S.A. 10:5-1 et seq. in that Plaintiff has been discriminated against on
account of her sex/gender and has been continuously subjected to a hostile work
environment that is severe and pervasive because of her sex/gender.
WHEREFORE, Plaintiff respectfully requests this Honorable Court:
i. Enter a declaratory judgment that Defendant’s acts complained of herein have
violated and continue to violate the rights of Plaintiff as secured by the United
States Constitution;
ii. Enjoin Defendant from continuing said practices;
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iii. Award Plaintiff compensatory damages including but not limited to: pain,
suffering, past economic loss, future economic loss, back pay, front pay, wage
increases, loss of life’s pleasures, loss of reputation, benefits, emotional distress
and other damages;
iv. Award reasonable costs and attorney’s fees;
v. Award punitive damages;
vi. Grant any other relief this Court deems just and proper under the circumstances.
JURY TRIAL DEMAND
Plaintiffs hereby demand a trial by jury on all issues so triable.
Respectfully submitted,
John J. Zidziunas
JOHN J. ZIDZIUNAS, ESQ.
LAW OFFICES OF JOHN J. ZIDZIUNAS, LLC
Dated: May 18, 2010