NEW Barisone Court Filing - 7/15/21

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Filed today (Part 1)
M01014
Christopher L. Deininger, Esq., N.J. Bar ID No. 004271996
DEININGER & ASSOCIATES, LLP
415 Route 10, Suite 1
Randolph, New Jersey 07869
(973) 879-1610; Fax (973) 361-1241
Attorneys for Plaintiff
MICHAEL L. BARISONE,
Plaintiff,
v.
WASHINGTON TOWNSHIP in Morris
County, New Jersey; POLICE OFFICER
BRIAN SZYMANSKI; POLICE
OFFICER DEREK HEYMER; POLICE
OFFICER BRIAN BIGHAM; POLICE
OFFICER MICHAEL HADE; POLICE
OFFICER PHILIP SEABECK; POLICE
OFFICER THOMAS FALLENI;
POLICE OFFICER ANDREW TESORI;
POLICE OFFICER JASON HENSLEY;
POLICE OFFICER MICHAEL
THOMPSON; POLICE OFFICER
ANTHONY COSTANTINO; POLICE
OFFICER ROGER GARRISON; JOHN
& JANE DOE 1-20, & ABC COMPANY
1-20,
Defendants.

SUPERIOR COURT
OF NEW JERSEY
LAW DIVISION – MORRIS
COUNTY
DOCKET NO.: MRS-L-______-21
COMPLAINT WITH JURY
DEMAND
Plaintiff MICHAEL L. BARISONE (“Plaintiff” and/or “BARISONE”), by and through his
attorneys DEININGER & ASSOCIATES, LLP, as and for his Complaint against the defendants,
makes the following allegations:
THE PARTIES & OTHER ACTORS

1. BARISONE is a 57-year-old Caucasian male who, at all times relevant hereto, had
   an established career as a top, Olympic trainer of horses and riders in the equestrian sport of
   dressage.
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2. At all times relevant hereto, BARISONE co-owned a farm located at 411 West
   Mill Road, Long Valley, New Jersey (the “Farm”), where BARISONE built and operated an
   Olympic-level, dressage horse farm and training facility, and thriving business.
3. At all times relevant hereto, the Farm had various visitors and/or occupants
   including but not limited to: (a) BARISONE and his partner Mary Haskins Gray (“Gray”),
   together with Gray’s minor children (the “children”); (b) Lauren S. Kanarek (“Kanarek”) and her
   boyfriend Robert G. Goodwin (“Goodwin”); © Ruth Cox (“Cox”); (d) Justin Hardin (“Hardin”),
   a long-term employee of BARISONE working and living at the Farm; and (e) numerous other
   persons who worked at the Farm, trained at the Farm, boarded horses at the Farm, and/or otherwise
   visited or occupied the premises.
4. Defendant WASHINGTON TOWNSHIP (“WASHINGTON TOWNSHIP”), is a
   municipality located in Morris County, New Jersey, where it operates, oversees, and/or manages
   various municipal services provided to its residents, including but not limited to public safety
   services provided by the Washington Township Police Department, located at 1 East Springtown
   Road, Long Valley, New Jersey 07853 (the “POLICE DEPARTMENT”); ambulance and
   associated medical services provided by a volunteer ambulance/EMT squad; and other services.
5. At all times relevant hereto, the following defendant-persons were members of the
   POLICE DEPARTMENT of WASHINGTON TOWNSHIP: (a) DEFENDANT POLICE
   OFFICER BRIAN SZYMANSKI (“SZYMANSKI”); (b) DEFENDANT POLICE OFFICER
   DEREK HEYMER (“HEYMER”); © DEFENDANT POLICE OFFICER BRIAN BIGHAM
   (“BIGHAM”); (d) DEFENDANT POLICE OFFICER MICHAEL HADE (“HADE”); (e)
   DEFENDANT POLICE OFFICER PHILIP SEABECK (“SEABECK”); (f) DEFENDANT
   POLICE OFFICER THOMAS FALLENI (“FALLENI”); (g) DEFENDANT POLICE OFFICER
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   ANDREW TESORI (“TESORI”); (h) DEFENDANT POLICE OFFICER JASON HENSLEY
   (“HENSLEY”); (i) DEFENDANT POLICE OFFICER MICHAEL THOMPSON
   (“THOMPSON”); (j) DEFENDANT POLICE OFFICER ANTHONY COSTANTINO
   (“COSTANTINO”); and (k) DEFENDANT POLICE OFFICER ROGER GARRISON
   (“GARRISON”). For purposes of this pleading, BARISONE may reference those persons
   collectively as the “POLICE OFFICER DEFENDANTS.”
6. Upon information and belief, at all times relevant hereto, each and every one of
   the POLICE OFFICER DEFENDANTS lived, resided, and/or worked in Morris County, New
   Jersey.
7. Now and at all times relevant hereto, fictitiously named defendants JOHN DOE &
   JANE DOE 1 through 20 are persons presently unknown who, individually, and/or in concert with
   the other defendants and/or other actors named here, and/or acting under the direction and control
   of one or more of the other defendants or actors named here, committed acts and omissions
   connected with injury and resulting damages caused to BARISONE.
8. Now and at all times relevant hereto, fictitiously named other defendants ABC
   COMPANY 1 through 20 corporations, partnerships, limited liability companies, and/or other
   types of entities, presently unknown which, individually, and/or in concert with the other
   defendants and/or actors named here, and/or acting under the direction and control of one or more
   of the other defendants or actors named here, committed acts and omissions connected with injury
   and resulting damages caused to BARISONE.
   ALLEGATIONS & CLAIMS
9. Commencing in or about the late 1990s, BARISONE became co-owner of the
   Farm and started transforming the property into a world-class training facility for dressage.
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10. Himself a one time, highly competitive dressage rider who had grown up in
    Upstate New York where he started riding at an early age, BARISONE had gravitated towards
    training riders and horses in dressage, investing years of time, training and effort to become one
    of the sport’s leading trainers.
11. BARISONE’s career reached a milestone when, at the 2016 Olympics held in
    Brazil, multiple competitors trained and/or coach by BARISONE won medals in the competitions.
    BARISONE operated a thriving business through which he trained riders and/or horses, raised
    horses, and/or boarded horse.
12. People interested in excelling in the sport of dressage sought out BARISONE to
    become their trainer, boarding their horses at the Farm (including certain horses valued in excess
    of $500,000), and coming there to train with BARISONE and his business in his world-class
    dressage barn with an adjoining club room, office, locker room, and other facilities.
13. The Farm included as well a farm house, which was a single-family residence
    divided into two living spaces under one roof with shared spaces and facilities, such as hallways,
    entrances, porches, and the like.
14. While the farm house could be characterized as having two living spaces, the fact
    was that the farm house constituted a single domicile, with its residents living like a single
    household.
15. The physical layout of the Farm included frontage on West Mill Road, with the
    farm house about 400 feet back from the road, and the dressage barn and training facility another
    1,600-1,700 feet up an unlit driveway behind the farm house.
16. Commencing in or about March 2018, Kanarek sought to become a pupil of
    BARISONE for purposes of training in dressage.
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17. With her parents’ financial support, Kanarek wanted to train with BARISONE and
    board her horse at the Farm during the summer season which covers (essentially) the months of
    April through September, following which (during the winter season) Kanarek would return to
    the Carolinas where she lived with her boyfriend Goodwin and boarded her horse(s).
18. Kanarek’s aspirational goal, upon information and belief, was to “train for the
    Olympics” and become a “world class” dressage rider, though the reality seemed more likely to
    be that Kanarek would remain an amateur who enjoyed the sport and the personal satisfaction one
    has when they take lessons and improve in a pursuit they love.
19. At that time Kanarek presented as an attractive, blond woman in her mid- to late
    30’s, with acceptable horseback riding skills, an acceptable horse, and what appeared to be nearly
    limitless financial support and backing of her father, a wealthy attorney from Livingston, New
    Jersey.
20. But there was an exceptionally dark and disturbing reality concerning Kanarek that
    was being hidden from view by Kanarek and her parents.
21. Unbeknownst the BARISONE, Kanarek had a history of domestic conflict
    following which she was banished from residing with her family.
22. Unbeknownst to BARISONE, Kanarek was a former heroin addict with a lengthy
    criminal history, including criminal assault.
23. Unbeknownst to BARISONE, Kanarek’s background included criminal
    harassment and stalking, including harassment that involved extensive use of the Internet and/or
    social media to make veiled and direct threats of injury, mayhem, violence, and criminal acts
    against persons with whom she was having interpersonal conflict.
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24. Unbeknownst to BARISONE, Kanarek’s tactics in the past included making false
    reports and false statements against people she perceived to be her “enemy,” to child-protectiveservices agencies and/or other governmental agencies, including the police.
25. Unbeknownst to BARISONE, Kanarek’s past included owning firearms and at
    least one incident of discharging her firearm, out of anger and rage, at other people and/or their
    personal property.
26. Unbeknownst the BARISONE, Safesport, the organization which purports to
    protect people from abuse and harassment within the pursuit of sports, had multiple complaints
    about Kanarek from persons Kanarek had harassed, stalked, and/or otherwise endeavored to
    “destroy.”
27. Unbeknownst the BARISONE, Kanarek’s boyfriend Goodwin had an equally
    disturbing past which included but was not limited to: drug addiction and heroin abuse; violence;
    criminal conduct; stalking; harassment; and the like.
28. But for BARISONE’s lack of knowledge of Kanarek’s hidden background,
    BARISONE would not have agreed to become her dressage trainer; would not have agreed to
    permit Kanarek’s horse(s) to board at the Farm; and/or would not have engaged in any other form
    of relationship with Kanarek as coach, trainer, house guest, or otherwise.
29. Similarly, but for BARISONE’s lack of knowledge of Goodwin’s hidden
    background, BARISONE would not have agreed to permit Kanarek to bring Goodwin to the Farm
    as her boyfriend and/or in any other capacity Kanarek and Goodwin might have proffered.
30. BARISONE himself has a medical history which includes psychological trauma
    from abuse as a child.
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31. At all times relevant hereto, BARISONE had been in treatment and/or counseling
    for his past trauma and status as a victim of child abuse and resulting trauma.
32. In that regard, BARISONE was an “egg shell” victim of future trauma who was
    vulnerable and susceptible to sustaining injury from harassment, stalking, verbal assault, and
    threats of violence from persons like Kanarek and/or Goodwin.
33. At all times relevant hereto, BARISONE displayed the traits, characteristics and
    affect of a person having psychological vulnerability and potential victimization from abuse, in
    need of protection from the police under circumstances indicating a basis for being in fear of
    injury, harm, violence, and/or threats of same.
34. Commencing in or about May 2019, Kanarek and Goodwin became temporary
    house guests of BARISONE in the farm house at the Farm.
35. BARISONE had told Kanarek that she could not become a tenant at the Farm due
    to water damage to the farm house which made it unlivable.
36. Upon being informed of that circumstance, Kanarek’s father commenced
    threatening BARISONE with abusive legal process and litigation, for purposes of forcing
    BARISONE to permit Kanarek to live at the Farm, even temporarily as BARISONE’s house
    guest.
37. Upon information and belief, Kanarek’s father did everything in his power to
    ensure that Kanarek and Goodwin would reside at the Farm (even temporarily) because Kanarek
    was banned from residing with her father and/or other immediate family in New Jersey due to
    Kanarek’s past history of violence, abuse, assault, drug use, psychotic behavior, and the like.
38. Separate and apart from that temporary “house guest” arrangement, Kanarek was
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    again boarding her horse in the barn at the Farm.
39. Soon after she started stay as a house guest at the Farm, Kanarek commenced
    displaying behavior towards BARISONE and/or Gray which was increasingly threatening and/or
    otherwise unacceptable.
40. Kanarek’s behavior included an upward spiral of harassment and stalking of
    BARISONE, Gray, and/or Gray’s children, both on the Internet and throughout social media like
    Facebook, where Kanarek made veiled and direct threats against them of ever-increasing severity.
41. As the situation escalated, BARISONE commenced uncovering the highly
    problematic and threatening criminal and social backgrounds of Kanarek and Goodwin.
42. It was in or about June 2019, for example, that BARISONE learned of Kanarek’s
    status as a drug addict, criminal, and person with a history of harassment, stalking, threats of
    violence, and violent assault, against others.
43. BARISONE and Gray began to observe, find, and/or otherwise become aware of
    Internet postings by Kanarek, in which Kanarek threatened harm, injury and/or violence against
    BARISONE, Gray, Gray’s minor children living at the Farm, and/or horses boarding in the barn.
44. As of July 31, 2019, and at all relevant times thereafter, BARISONE’s affect,
    statements and behaviors evidenced, outwardly, that BARISONE was being psychologically
    assaulted and victimized by Kanarek and Goodwin, such that the defendants knew, intentionally
    disregarded and/or recklessly disregarded, BARISONE’s mounting psychological distress and
    potential psychiatric breakdown that could occur unless appropriate and sufficient action was
    taken by the defendants to intervene.
    The July 31, 2019 Incident
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45. The situation continued to escalate, out of control, with Kanarek increasing her
    terroristic threats, harassment, stalking, and/or other criminal behaviors until the night of July 31,
    2019, when BARISONE made his first “911” call to the WASHINGTON TOWNSHIP POLICE
    DEPARTMENT seeking emergency assistance.
46. On July 31, 2019, at approximately 20:00 hours, BARISONE called “911” and
    reported that he had been assaulted verbally by Kanarek and/or Goodwin; that he and others at
    the Farm were being subjected to other criminal behaviors by Kanarek and/or Goodwin, including
    but not limited to behaviors which constituted unlawful criminal threats, harassment, cyber
    stalking, and cyber harassment; their fear; and other relevant information.
47. Thereafter, DEFENDANT TESORI and DEFENDANT SEABECK arrived at the
    Farm, whereupon BARISONE and/or others repeated their reports to WASHINGTON
    TOWNSHIP that there had been a verbal assault by Kanarek and/or Goodwin; that BARISONE
    and others at the Farm were being subjected to other criminal behaviors by Kanarek and/or
    Goodwin including but not limited to behaviors which constituted unlawful criminal threats,
    harassment, cyber stalking, and cyber harassment; and that BARISONE and others were in fear
    of immediate danger and injury to their physical health, wellbeing and/or the wellbeing of their
    property.
48. DEFENDANT TESORI and DEFENDANT SEABECK intentionally disregarded
    the facts and circumstances being reported to them and intentionally failed to act to protect
    BARISONE and/or the others making the report to WASHINGTON TOWNSHIP against
    Kanarek and Goodwin.
49. For example, during the July 31, 2019 incident, BARISONE’s affect, statements
    and behaviors evidencing, outwardly, that BARISONE was being psychologically assaulted and
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    victimized by Kanarek and Goodwin, such that the police knew, intentionally disregarded and/or
    recklessly disregarded, BARISONE’s mounting psychological distress and potential psychiatric
    breakdown that could occur unless appropriate and sufficient action was taken by the defendants
    to intervene in the developing criminal dispute.
50. Thereafter, DEFENDANT TESORI and DEFENDANT SEABECK intentionally
    authored and issued a Washington Twp Police Department Investigation Report that was
    materially false and misleading (the “August 1, 2019 Police Report”).
51. The August 1, 2019 Police Report was materially false and misleading in that the
    report, inter alia: (a) failed to document the complaint by BARISONE and the others that some of
    them were in fear of immediate danger and injury to their physical health, wellbeing and/or the
    wellbeing of their property; and/or (b) failed to document other facts and circumstances necessary
    to accurately and effectively convey the true circumstances and resulting material threat of injury,
    harm, and/or other mayhem occurring at the Farm that day.
    The August 1, 2019 Incident
52. The situation continued to escalate, out of control, with Kanarek increasing her
    terroristic threats, harassment, stalking, and/or other criminal behaviors, causing BARISONE to
    make his second “911” call to the WASHINGTON TOWNSHIP POLICE DEPARTMENT
    seeking emergency assistance.
53. On August 1, 2019, at approximately 18:00 hours, BARISONE called “911” and
    again reported that he had been assaulted verbally by Kanarek and/or Goodwin; that he and others
    at the Farm were being subjected to other criminal behaviors by Kanarek and/or Goodwin,
    including but not limited to behaviors which constituted unlawful criminal threats, harassment,
    cyber stalking, and cyber harassment; their fear; and other relevant information.
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54. Thereafter, DEFENDANT HENSLEY and DEFENDANT SEABECK arrived at
    the Farm and, upon information and belief, in abject violation of standard police protocol, policy
    and procedure, interviewed Kanarek and Goodwin before the DEFENDANT POLICE
    OFFICERS interviewed BARISONE, the criminal complainant who called “911.”
55. When DEFENDANT HENSLEY and DEFENDANT SEABECK finally did
    interview BARISONE and/or the others being threatened by Kanarek and/or Goodwin,
    BARISONE and/or others reported to WASHINGTON TOWNSHIP that there had been a verbal
    assault by Kanarek and/or Goodwin; that BARISONE and others at the Farm were being subjected
    to other criminal behaviors by Kanarek and/or Goodwin including but not limited to behaviors
    which constituted unlawful criminal threats, harassment, cyber stalking, and cyber harassment;
    and that BARISONE and others were in fear for their lives and in fear of immediate danger and
    injury to their physical health and wellbeing, and/or to the wellbeing of their property.
56. DEFENDANT HENSLEY and DEFENDANT SEABECK intentionally
    disregarded the facts and circumstances being reported to them and intentionally failed to take
    appropriate action choosing instead to avoid their duty to act by falsely characterizing the situation
    as a “private dispute,” a tactic those defendants, the other defendants, and particularly defendant
    WASHINGTON TOWNSHIP, utilized unlawfully as a practice, custom, and/or unofficial policy.
57. For example, during the August 1, 2019 incident, BARISONE’s affect,
    statements, and behaviors evidencing, outwardly, that BARISONE was being psychologically
    assaulted and victimized by Kanarek and Goodwin, such that the police knew, intentionally
    disregarded, and/or recklessly disregarded BARISONE’s mounting psychological distress and
    likely psychiatric breakdown that was going to occur unless appropriate and sufficient action was
    taken by the defendants to intervene in what was obviously a police matter and not a “private
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    dispute.”
58. Thereafter, DEFENDANT HENSLEY and DEFENDANT SEABECK
    intentionally authored and issued a Washington Twp Police Department Investigation Report that
    was materially false and misleading (the “August 2, 2019 Police Report”).
59. The August 2, 2019 Police Report was materially false and misleading in that the
    report, inter alia: (a) failed to document the complaints by BARISONE and the others that they
    were in fear for their lives and/or in fear of immediate danger and injury to their physical health
    and wellbeing, and/or to the wellbeing of their property; and/or (b) failed to document other facts
    and circumstances necessary to accurately and effectively convey the true circumstances and
    resulting material threat of injury, harm, and/or other mayhem occurring at the Farm that day.
60. In connection with their responds to BARISONE’s August 1, 2019 “911” call and
    their visit to the Farm, DEFENDANT SEABECK contacted a Morris County Assistant Prosecutor
    for purposes of discussing the August 1, 2019 incident with the Morris County Prosecutor’s Office
    (“MCPO”).
61. During that call with MCPO, DEFENDANT SEABECK failed intentionally to
    make a truthful and/or accurate report of the August 1, 2019 incident at the Farm, which
    inaccuracies included, but were not limited to, the failure of WASHINGTON TOWNSHIP to
    report that BARISONE and others had expressed that they were in fear for their lives and/or in
    fear of immediate danger and injury to their physical health and wellbeing, and/or to the wellbeing
    of their property, from harm threatened by Kanarek and/or Goodwin.
62. Upon information and belief, the intentional inaccurate reporting of the August 1,
    2019 incident was part of a practice, custom and policy adopted by WASHINGTON TOWNSHIP
    to endeavor to limit police involvement by falsely characterizing as “civil matters” and/or “private
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    disputes” incidents which, in fact, were criminal in nature.
63. There are other residents of WASHINGTON TOWNSHIP who have been
    subjected to the same illegal and unlawful treatment by WASHINGTON TOWNSHIP and its
    POLICE DEPARTMENT.
    The August 3, 2019 Incident
64. The situation continued to escalate, out of control, with Kanarek increasing her
    terroristic threats, harassment, stalking, and/or other criminal behaviors, causing BARISONE to
    make his third “911” call to the WASHINGTON TOWNSHIP POLICE DEPARTMENT seeking
    emergency assistance.
65. On August 3, 2019, at approximately 9:00 hours, BARISONE called “911” and
    again reported that he and others at the Farm were being assaulted verbally by Kanarek and/or
    Goodwin; that he and others at the Farm were being subjected to other criminal behaviors by
    Kanarek and/or Goodwin, including but not limited to behaviors which constituted unlawful
    criminal threats, harassment, cyber stalking, and cyber harassment; their fear; and other relevant
    information.
66. Thereafter, DEFENDANT THOMPSON and DEFENDANT FALLENI arrived at
    the Farm and, upon information and belief, in abject violation of standard police protocol, policy
    and procedure, interviewed Kanarek and Goodwin before the DEFENDANT POLICE
    OFFICERS interviewed BARISONE, the criminal complainant who called “911.”
67. When DEFENDANT THOMPSON and DEFENDANT FALLENI finally did
    interview BARISONE and/or the others being threatened by Kanarek and/or Goodwin,
    BARISONE and/or others reported to WASHINGTON TOWNSHIP that there had been a verbal
    assault by Kanarek and/or Goodwin; that BARISONE and others at the Farm were being subjected
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    to other criminal behaviors by Kanarek and/or Goodwin including but not limited to behaviors
    which constituted unlawful criminal threats, harassment, cyber stalking, and cyber harassment;
    and that BARISONE and others were in fear for their lives and in fear of immediate danger and
    injury to their physical health and wellbeing, and/or to the wellbeing of their property.
68. For example, BARISONE and/or the other victims reported expressly to the
    responding POLICE OFFICER DEFENDANTS a number of material, salient facts which they
    chose intentionally to disregard, including the following:
    (a) Kanarek was believed to have possession of, and/or current access to, a loaded
    firearm;
    (b) Kanarek had a history of threatening to discharge and/or actually discharging her
    loaded firearm at people and property for the purpose of causing harm, injury
    and/or damage;
    © Kanarek threatened BARSIONE and others that Kanarek was coming to attack
    them with “weapons hot,” meaning that she was armed and ready to discharge a
    firearm at one or more of them;
    (d) Kanarek was making threats of harm, physical harm, violence, and/or mayhem
    against BARISONE, Gray, and/or others, in writing, on the Internet through
    social media posting which were and/or could be made available for the
    DEFENDANT POLICE OFFICERS to see; and/or,
    (e) Kanarek had a criminal history, history as a drug addict, and other personal
    history demonstrating that Kanarek was a clear, immediate, and present danger
    to BARISONE, Gray, Gray’s children, others at the Farm, and/or horses being
    boarded at the Farm.
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69. During the August 3, 2019 Incident, Kanarek and/or Goodwin expressly told the
    responding DEFENDANT POLICE OFFICERS that Kanarek/Goodwin had place electronic
    devices on the premises, permitting Kanarek and Goodwin to intercept and thereafter disclose
    private oral communications BARISONE, Gray, and/or others were having at the Farm
    (hereinafter, the “Eavesdropping”).
70. The placement of those devices without consent of the property owner, upon
    information and belief, is criminal trespassing under New Jersey law.
71. The Eavesdropping was unlawful under New Jersey law.
72. Moreover, the disclosure of unlawfully intercepted oral communications is a crime
    under New Jersey law.
73. Nevertheless, the responding DEFENDANT POLICE OFFICERS failed to
    investigate the criminal acts Goodwin has reported to them he had been committing, failed to take
    other appropriate non-discretionary action in response to notification that such criminal conduct
    was occurring, and intentionally failed to intervene.
74. DEFENDANT THOMPSON and DEFENDANT FALLENI intentionally
    disregarded all of those facts and circumstances being reported to them and intentionally failed to
    act to intervene in what obviously was a police matter and not just a “private dispute.”
75. Those POLICE OFFICER DEFENDANTS also disregarded, during the August 3,
    2019 incident, BARISONE’s affect, statements, and behaviors evidencing, outwardly, that
    BARISONE was being psychologically assaulted and victimized by Kanarek and Goodwin, such
    that the police knew, intentionally disregarded, and/or recklessly disregarded BARISONE’s
    mounting psychological distress and likely psychiatric breakdown about to occur unless
    appropriate and sufficient action was taken by the defendants to intervene.
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76. Thereafter, DEFENDANT THOMPSON and DEFENDANT FALLENI
    intentionally authored and issued a Washington Twp Police Department Investigation Report that
    was materially false and misleading (the “August 8, 2019 Police Report”).
77. The August 8, 2019 Police Report was materially false and misleading in that the
    report, inter alia: (a) failed to document the complaint by BARISONE and the others that some of
    them were in fear for their lives and in fear of immediate danger and injury to their physical health
    and wellbeing, and/or the wellbeing of their property; (b) failed to document the facts and
    circumstances concerning Kanarek’s actual or potential possession of a firearm, and her threats
    to use the firearm against BARISONE and others by coming for them with “weapons hot”; and/or
    © failed to document other facts and circumstances necessary to accurately and effectively
    convey the true circumstances and resulting material threat of injury, harm, and/or other mayhem
    occurring at the Farm that day.
78. In connection with their responds to BARISONE’s August 3, 2019 “911” call and
    their visit to the Farm, the responding DEFENDANT POLICE OFFICERS failed to contact the
    MCPO and/or any of its assistant prosecutors for purposes of discussing the August 3, 2019
    incident and/or reporting to the MCPO the escalating, increasingly dangerous situation at the
    Farm.
79. Upon information and belief, the intentional inaccurate reporting of the August 3,
    2019 incident was another example of the practice, custom and policy adopted by
    WASHINGTON TOWNSHIP to endeavor to limit police involvement by falsely characterizing
    as “civil matters” and/or “private disputes” incidents which, in fact, were criminal in nature.
80. Upon information and belief, had the defendants (especially the responding
    DEFENDANT POLICE OFFICERS) acted appropriately in response to BARISONE’s criminal
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    complaint and “911” emergency call on August 3, 2019, the defendants would have discovered
    that in the early morning hours on or about August 3, 2019, Goodwin was conducting Internet
    searches in an effort to find address information for the location where Gray’s children were about
    to be attending a family reunion; that Goodwin and Kanarek were stalking Gray’s children for
    criminal, deviant and illegal purposes; and that there was probable cause to intervene in the
    situation which was not a private dispute but, rather, a criminal matter.
    The August 4, 2019 Incident
81. The situation continued to escalate, out of control, with Kanarek increasing her
    terroristic threats, harassment, stalking, and/or other criminal behaviors, causing BARISONE to
    make his fourth “911” call to the WASHINGTON TOWNSHIP POLICE DEPARTMENT
    seeking emergency assistance.

[eggbutt]

Part 2:

82. On August 4, 2019, at approximately 16:00 hours, BARISONE called “911” and
    again reported (now for the fourth time, at least) that he and others at the Farm were being
    assaulted verbally by Kanarek and/or Goodwin; that he and others at the Farm were being
    subjected to other criminal behaviors by Kanarek and/or Goodwin, including but not limited to
    behaviors which constituted unlawful criminal threats, harassment, cyber stalking, and cyber
    harassment; and other relevant information demonstrating that the dispute that BARISONE and
    others were in fear of immediate danger and injury to their physical health, wellbeing and/or the
    wellbeing of their property.
83. While BARISONE was on the phone with the “911” operator, Goodwin could be
    heard in the background of the phone call, screaming terroristic threats against BARISONE and
    Cox, including words to the effect that Goodwin would harm BARISONE and would “take down”
    Cox should she attempt to intervene – words which reasonably placed BARISONE, Cox and
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    others in fear for their lives from violence against them by Kanarek and/or Goodwin.
84. BARISONE expressly told the “911” operator that he, Gray, and the others were
    in fear, as the operator (had he/she been listening) could hear Goodwin screaming his threats
    violence and mayhem in the background.
85. Thereafter, DEFENDANT BIGHAM arrived at the Farm, followed soon after that
    DEFENDANT CONSTANTINO.
86. In abject violation of standard police protocol, policy and procedure,
    DEFENDANT BIGMAN interviewed Kanarek and Goodwin before the DEFENDANT POLICE
    OFFICERS interviewed BARISONE, the criminal complainant who called “911.”
87. When DEFENDANT CONSTANTINO and DEFENDANT BIGHAM finally did
    interview BARISONE and/or the others being threatened by Kanarek and/or Goodwin,
    BARISONE and/or others reported to WASHINGTON TOWNSHIP that there had been a verbal
    assault by Kanarek and/or Goodwin; that BARISONE and others at the Farm were being subjected
    to other criminal behaviors by Kanarek and/or Goodwin including but not limited to behaviors
    which constituted unlawful criminal threats, harassment, cyber stalking, and cyber harassment;
    and that BARISONE and others were in fear of immediate danger and injury to their physical
    health, wellbeing and/or the wellbeing of their property.
88. For example, BARISONE, Cox and others recounted to the responding
    DEFENDANT POLICE OFFICERS that Goodwin and Kanarek made threats of violence against
    them, and they were in fear for their lives.
89. As he had done numerous times in the past during the prior incidents, BARISONE
    informed the responding DEFENDANT POLICE OFFICERS that if they were going to do
    nothing BARISONE wanted to speak to a supervisor, such as a Sargent and/or Detective.
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    BARISONE’s request, once again, was rejected by the responding DEFENDANT POLICE
    OFFICERS who said “no”.
90. BARISONE again advised WASHINGTON TOWNSHIP (through the responding
    DEFENDANT POLICE OFFICERS) of many other material, salient facts which the defendants
    chose intentionally to disregard, including the fact that Kanarek was believed to have possession
    of, and/or current access to, a loaded firearm.
91. DEFENDANT COSTANTINO and DEFENDANT BIGHAM intentionally
    disregarded all of those the facts and circumstances being reported to them and intentionally failed
    to act to intervene on behalf of BARISONE and/or the others making the report to
    WASHINGTON TOWNSHIP against Kanarek and Goodwin.
92. Those POLICE OFFICER DEFENDANTS also disregarded, during the August 4,
    2019 incident, BARISONE’s affect, statements, and behaviors evidencing, outwardly, that
    BARISONE was being psychologically assaulted and victimized by Kanarek and Goodwin, such
    that the defendants knew, intentionally disregarded, and/or recklessly disregarded BARISONE’s
    mounting psychological distress was about to cause a psychiatric breakdown because appropriate
    and sufficient action was taken by the defendants to intervene in what obviously was a criminal
    matter, not a private dispute.
93. Thereafter, DEFENDANT CONTANTINO and DEFENDANT BIGHAM
    intentionally authored and issued a Washington Twp Police Department Investigation Report that
    was materially false and misleading (the “August 4, 2019 Police Report”).
94. The August 4, 2019 Police Report was materially false and misleading in that the
    report, inter alia: (a) failed to document the complaint by BARISONE and the others that some of
    them were in fear for their lives and in fear of immediate danger and injury to their physical health
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    and wellbeing, and/or to the wellbeing of their property; (b) failed to document the facts and
    circumstances concerning Kanarek’s access to and threats to use a loaded firearm against
    BARISONE and others; and/or © failed to document other facts and circumstances necessary to
    accurately and effectively convey the true circumstances and resulting material threat of injury,
    harm, and/or other mayhem occurring at the Farm that day.
95. In connection with their responds to BARISONE’s August 4, 2019 “911” call and
    their visit to the Farm, the responding DEFENDANT POLICE OFFICERS failed to contact the
    MCPO and/or any of its assistant prosecutors for purposes of discussing the August 4, 2019
    incident and/or reporting to the MCPO the escalating, increasingly dangerous situation at the
    Farm.
96. Upon information and belief, the intentional inaccurate reporting of the August 4,
    2019 incident was another example of the practice, custom and policy adopted by
    WASHINGTON TOWNSHIP to endeavor to limit police involvement by falsely characterizing
    as “civil matters” and/or “private disputes” incidents which, in fact, were criminal in nature.
    The August 5, 2019 Incident
97. On August 5, 2019, at or about 16:00 hours, BARISONE drove to the
    WASHINGTON TOWNSHIP POLICE DEPARTMENT building to speak directly to an officer
    of supervisory authority.
98. BARISONE’s purpose was to speak to a detective, the Police Chief, and/or
    someone else above the level of the responding DEFENDANT POLICE OFFICERS, to
    personally again advised WASHINGTON TOWNSHIP of the true state of facts, circumstances,
    and affairs at the Farm, including but not limited to Kanarek’s firearms threats, and the fact that
    BARISONE and others at the Farm were in fear for their lives.
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99. Upon entering the building BARISONE approached the receptionist and expressly
    asked to see the Police Chief (answer, “no”), asked for the Police Chief’s phone number (answer,
    “no”), and advised her of other material information about the dangerous situation at the Farm
    that WASHINGTON TOWNSHIP and its responding DEFENDANT POLICE OFFICERS were
    intentionally ignoring.
100. BARISONE said to the receptionist, in sum and substance, words to the effect that
     “I have a HUGE problem at the Farm … I have called this place 15 times looking to speak to a
     human … No one has EVER picked up … I have left messages … No one has EVER called me
     back … My family and I are in danger … in fear for our lives …I NEED to speak to an official
     NOW.”
101. As he spoke those words BARISONE displayed the affect of a person on the verge
     of having a mental/emotional/psychological breakdown; he was visibly shaking, visibly agitated,
     visibly upset, and visibly demonstrating the affect of a person in fear for his life and the lives of
     others.
102. Minutes later three uniformed officers confronted BARISONE in the lobby where
     he stood. The officers appeared to be some of the DEFENDANT POLICE OFFICERS
     encountered by BARISONE when WASHINGTON TOWNSHIP came to the Farm on the prior
     “911” calls.
103. The DEFENDANT POLICE OFFICERS, with hands on their belts (indicating that
     weapons could be drawn against BARISONE), stood stone-faced staring at BARISONE, pushing
     out their chests, doing whatever they could to intimidate him.
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104. Nevertheless, BARISONE mustered the courage to confront the officers, telling
     them, in words and/or in substance, the following:
     I NEED a supervisor. A Detective. We are in danger. I have
     LUNATICS attacking me and my family at the Farm. They
     are drug addicts. They are violent criminals. They have
     guns. They are posting deadly threats against us on social
     media. We need protection. They have been served vacate
     orders today. There WILL be trouble. WE ARE IN FEAR
     FOR OUR LIVES. What they are posting is JUST LIKE
     Parkland School. They WILL harm us. I need a mental
     health professional to look at this stuff. I have papers in my
     truck in the parking lot showing the threats and violent
     messages they are posting. I need a ranking officer to deal
     with this situation. It is your job. WE ARE IN FEAR FOR
     OUR LIVES.”
105. Throughout his speech to the police officers in the lobby during this incident
     BARISONE was visibly shaking, visibly agitated, visibly in fear, visibly distressed, and visibly
     evidencing multiple signs of emotional/psychological/psychiatric distress being caused by
     WASHINGTON TOWNSHIP’s intentional mishandling of the circumstances.
106. Despite those compelling circumstances and statements, the responding
     DEFENDANT POLICE OFFICES which BARISONE confronted in the lobby of the Police
     Department that afternoon intentionally ignored the facts and circumstances, intentionally
     blocked BARISONE from speaking with a supervisor above them in rank, intentionally
     mischaracterized the situation as a “private dispute,” intentionally refused to aid or assist
     BARISONE, and forced him to leave the building without permitting him to speak to anyone
     having supervisory authority over them and/or the situation at the Farm.
107. Upon information and belief, on behalf of WASHINGTON TOWNSHIP, those
     responding DEFENDANT POLICE OFFICERS failed intentionally to write up any police report
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     23
     of this incident, choosing instead to intentionally hide it from the record of what was occurring
     up at the Farm. That was yet another intentional wrong perpetrated by the defendants.
108. Those POLICE OFFICER DEFENDANTS intentionally disregarded
     BARISONE’s affect, statements, and behaviors evidencing, outwardly, that BARISONE was
     being psychologically assaulted and victimized by Kanarek and Goodwin, such that the police
     knew, intentionally disregarded, and/or recklessly disregarded BARISONE’s mounting
     psychological distress and that BARISONE was on the verge of experiencing a psychiatric
     breakdown arising from the defendants’ refusal to take appropriate and sufficient action to
     intervene in what obviously was a criminal matter and not a private dispute.
     The August 6, 2019, Midday Incident
109. On August 6, 2019, at or about 13:00 hours, WASHINGTON TOWNSHIP
     descended upon the Farm with a line of official vehicles and township actors.
110. WASHINGTON TOWNSHIP proceeded to invade the premises in response to a
     complaint Kanarek and Goodwin made to WASHINGTON TOWNSHIP that the buildings on the
     Farm had unpermitted renovations, alterations, and/or construction work being performed and/or
     performed in the past.
111. Had the defendants truly believed that what was occurring at the Farm was a
     “private matter,” “private dispute,” and/or other non-police matter, defendants would not have
     undertaken such an extreme intervention in response to Kanarek’s complaint.
112. The reports made by Kanarek and Goodwin were part of the stalking and
     harassment they were directing and BARISONE, Gray, and other peaceful residents/visitors at
     the Farm, only now Kanarek and Goodwin were committing those unlawful acts with the active
     participation and assistance of WASHINGTON TOWNSHIP.
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113. Fearful, shaken, and in distress as a result of the totality of the circumstances,
     BARISONE was visibly shaking while he repeatedly told the WASHINGTON TOWNSHIP
     officials present that BARISONE, Gray, and the others were in fear for their lives due to acts and
     threats of Kanarek and Goodwin, and the abject failure and refusal of WASHINGTON
     TOWNSHIP and/or the DEFENDANT POLICE OFFICERS to take appropriate action.
114. During the encounter, BARISONE spoke expressly to the WASHINGTON
     TOWNSHIP Chief Building Inspector who was present that day (the “Chief Building Inspector”),
     who confirmed verbally to other WASHINGTON TOWNSHIP officials that Kanarek and
     Goodwin would not qualify as “tenants” at the Farm.
115. Therefore, at that point in time, the defendants had actual knowledge that the
     occurrence at the Farm occurring since July 31, 2019, were not a “private,” “landlord-tenant”
     dispute they could sidestep to avoid taking non-discretionary action to intervene.
116. Nevertheless, the defendants persisted, intentionally, in their disregard of the
     complaints being made against Kanarek and Goodwin by BARISONE, Gray and the other at the
     Farm.
117. WASHINGTON TOWNSHIP issued orders that various living spaces occupied
     on the Farm were ordered to be vacated immediately until further notice, and that WASHINGTON
     TOWNSHIP would return later in the day to confirm whether BARISONE, Grey, Kanarek and
     Goodwin had, in fact, vacated the buildings.
118. Having issued such an order, it was the duty and obligation of WASHINGTON
     TOWNSHIP to force Kanarek and Goodwin to vacate the Farm house; but when BARISONE
     requested that WASHINGTON TOWNSHIP do just that, WASHINGTON TOWNSHIP refused
     and directed BARISONE that it was his obligation to physically eject them. BARISONE advised
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     WASHINGTON TOWNSHIP at that time, once again, that he was in fear for his life from
     violence threatened against him by Kanarek and Goodwin, which WASHINGTON TOWNSHIP
     again ignored intentionally.
119. During and throughout this incident, WASHINGTON TOWNSHIP and its
     officials in attendance intentionally disregarded BARISONE’s affect, statements, and behaviors
     evidencing that BARISONE was being psychologically assaulted and victimized by Kanarek and
     Goodwin, such that the police knew, intentionally disregarded, and/or recklessly disregarded
     BARISONE was now experiencing profound psychological distress and was likely in the process
     of experiencing a psychiatric breakdown.
     The August 6, 2019 Evening Incident
120. On August 6, 2019, at or about 17:00 p.m., WASHINGTON TOWNSHIP again
     descended upon the Farm with a line of official vehicles and township actors.
121. Utilizing its building inspector, fire marshal, and police, WASHINGTON
     TOWNSHIP proceeded to invade the premises again to determine whether, in fact the living
     spaces had been vacated as ordered by WASHINGTON TOWNSHIP.
122. Fearful, shaken, and in distress as a result of the totality of the circumstances,
     BARISONE was visibly shaking while he repeatedly told the WASHINGTON TOWNSHIP
     officials present that BARISONE, Gray, and the others were in fear for their lives due to acts and
     threats of Kanarek and Goodwin, and the abject failure and refusal of WASHINGTON
     TOWNSHIP and/or the DEFENDANT POLICE OFFICERS to take appropriate action.
123. BARISONE advised WASHINGTON TOWNSHIP that he had advised Kanarek
     and Goodwin to vacate, but that they had refused, and that BARISONE and the others remained
     in fear for their lives. WASHINGTON TOWNSHIP’s officials refused to take any action and, in
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     fact, some of them even laughed at BARISONE and his request.
124. It was following that discussion that WASHINGTON TOWNSHIP officials
     sought access to the Farm house to enter the area Kanarek and Goodwin were occupying.
125. WASHINGTON TOWNSHIP took Cox to the Farm house to make that entry,
     whereupon Cox was viciously attacked and bitten by Kanarek’s violent dog.
126. A WASHINGTON TOWNSHIP ambulance was called to the scene, whereupon
     Cox was treated for the dog bite.
127. During their visit to the Farm, one or more of the WASHINGTON TOWNSHIP
     ambulance attendants observed BARISONE sufficiently to note that BARISONE’s affect,
     statements, and behaviors evidenced, outwardly, psychological distress and psychiatric
     breakdown likely to occur unless appropriate and sufficient action was taken by WASHINGTON
     TOWNSHIP to intervene.
128. The police officers in attendance during this incident, namely DEFENDANT
     OFFICER GARRISON and DEFENDANT OFFICER HADE, intentionally disregarded the
     situation and falsely reported about the material facts and circumstances following the incident,
     including false reporting in the August 11, 2019, written police report they authored/approved
     which was materially, intentionally, false, and misleading.
     The August 7, 2019 Incident
129. On August 7, 2019, following the aforementioned protracted, intentional, derelict
     interactions which WASHINGTON TOWNSHIP and the DEFENDANT POLICE OFFICERS
     had with BARISONE, Kanarek, Goodwin, and/or others at the Farm, there was an incident at the
     Farm in which Kanarek was shot twice in the chest (the “August 7, 2019 Incident”).
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130. BARISONE was indicted for the August 7, 2019, Incident, was charged
     criminally, and is presently being held in jail awaiting trial.
131. BARISONE has no recollection of the shooting and has entered a “not guilty” plea.
132. A renowned, board-certified psychiatrist has determined that BARISONE was
     mentally incompetent at the time of the August 7, 2019, Incident, having suffered from mental
     disease, condition, and/or defect which, in sum and/or substance, rendered BARISONE to be
     insane.
     Other Allegations
133. The aforementioned acts, actions, and omissions of the defendant public employees
     (including but not limited to the DEFENDANT POLICE OFFICERS) constituted crimes, acts of
     commission and omission committed with actual malice against BARISONE, and/or acts of
     commission and omission constituting willful misconduct.
134. The aforementioned acts, actions, and omissions of the defendant public employees
     (including but not limited to the DEFENDANT POLICE OFFICERS) constituted acts of
     commission and omission of “official misconduct” made criminal under N.J.S.A. § 59:3-14.
135. The aforementioned acts, actions, and omissions of the defendant public employees
     (including but not limited to the DEFENDANT POLICE OFFICERS) included a conspiracy to
     violate BARISONE’s protected rights and interests, including violations arising from the
     preparation and submission of false police reports to concealing the true state of affairs and
     occurrences at the Farm between July 31, 2019 and August 7, 2019.
     Civil Rights Violations
136. Under the New Jersey Civil Rights Act N.J.S.A. §10:6-2, and/or under 42 U.S.C.
     §1983, it is unlawful for WASHINGTON TOWNSHIP, the DEFENDANT POLICE OFFICERS,
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     and/or the other defendants, to perpetrate acts, actions, and omissions, resulting in the unlawful
     deprivations of, unlawful interferences with, and/or unlawful attempted interferences with,
     BARISONE’s rights, privileges, immunities, and interests (collectively, the “rights”) under the
     U.S. Constitution and/or under the New Jersey Constitution.
137. During and in connection with the aforementioned incidents, WASHINGTON
     TOWNSHIP, the DEFENDANT POLICE OFFICERS (acting under color of law), and/or the other
     defendants, committed intentional acts, actions, and omissions which were the direct and
     proximate cause of injury to BARISONE by and through the deprivation, interference with, denial
     of, and violation of BARISONE’s rights under the New Jersey State Constitution and/or under the
     U.S. Constitution.
138. The unlawful acts, actions, and omissions were perpetrated against BARISONE for
     the purpose of depriving him of his constitutionally protected rights, and/or for the purpose of
     interfering with and/or attempting to interfere with same, include but were not limited to the
     following:
     (a) The unlawful, intentional falsification of written reports and statements
     concerning, about and/or against BARISONE which were created, drafted, executed, and
     publicized for the unlawful purpose of depriving, interfering with, or attempting to interfere
     with, BARISONE’s protected civil rights;
     (b) The unlawful intentional retaliation against BARISONE for his exercise of
     his protected constitutional rights, including but not limited to BARISONE’s right to
     operate his business and the Farm, his right to make reports of wrongdoing to senior
     members of the WASHINGTON TOWNSHIP Police Department;
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     © The unlawful intentional failure to conduct to completion, appropriate
     investigations of complaints filed by BARISONE with WASHINGTON TOWNSHIP
     and/or with the DEFENDANT POLICE OFFICERS, and/or matters referred to and
     reported to the Morris County Prosecutor’s Office;
     (d) The defendants’ intentional, deliberate, persistent false characterization of
     the occurrences at the Farm being reported to the defendants as private disputes between a
     landlord and tenant, when, in reality, the occurrences were police matters that required the
     intervention of law enforcement;
     (e) WASHINGTON TOWNSHIP’s failure to properly train, monitor, manage,
     supervise, and/or control its municipal officials, officers, employees, and/or agents
     (including people acting under color of law), which caused and resulted in the mistreatment
     of BARISONE and/or unlawful violations of his rights;
     (f) The defendants’ intentional, deliberate, persistent failure to treat
     BARISONE with fairness, compassion, and respect, as a victim of crime and/or criminal
     conduct; and
     (g) Other unlawful acts, actions, and omissions which violated the New Jersey
     Civil Rights Act and/or 42 U.S.C. § 1983.
139. The specific constitutionally protected civil rights BARISONE is asserting to have
     been deprived, interfered with, and/or attempted to be interfered with, by WASHINGTON
     TOWNSHIP, by the DEFENDANT POLICE OFFICERS, and/or by the other defendants, include
     but are not limited to the following:
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     (a) BARISONE’s civil right to freedom of speech, including his right to make
     reports to the police which, as a matter of law, were to be conveyed accurately and
     completely to others as a non-discretionary duty the defendants owed BARISONE;
     (b) BARISONE’s civil right to file and pursue appropriate petitions with the
     government (including reports of crime and/or emergency calls) and to have those petitions
     addressed fully, completely, expeditiously, lawfully, and appropriately;
     © BARISONE’s civil right to equal protection under the law;
     (d) BARISONE’s civil right to exist free from unlawful retaliation directed at
     him for exercising his constitutionally protected rights and interests, including freedom for
     retaliation in the form of intentional dereliction of duty in the performance of responding
     to “911” calls and reports of emergencies that require police intervention;
     (e) BARISONE’s New Jersey constitutional right to protect his reputation and
     good name;
     (f) BARISONE’s right under Article 1, Section 22 of the New Jersey
     Constitution and under N.J.S.A. § 52:4B-36, as a victim of crime, to be treated with
     fairness, compassion, respect, and the like, arising from and in connection with the criminal
     acts being perpetrated against BARISONE by Kanarek, Goodwin, and/or the
     DEFENDANT POLICE OFFICERS;
     (g) BARISONE’s substantive due process rights, procedural due process rights,
     and/or other statutory and constitutional rights, under N.J.S.A. §§ 2C:25-19 et. seq., as a
     victim of domestic violence perpetrated against him by Kanarek and/or Goodwin;
     BARISONE’s rights as a victim of unlawful, criminal interception of wire, electronic,
     and/or oral communications and the contents thereof perpetrated by Kanarek and/or
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     Goodwin at the Farm, and BARISONE’s rights as a victim of the crime of “official
     deprivation of civil rights” as defined under N.J.S.A. §§ 2C:30-6; and/or
     (h) Other civil rights and interests with which BARISONE is vested by and/or
     through the U.S. Constitution and/or the New Jersey Constitution.
140. As a direct and proximate result of the unlawful acts, actions, and omissions
     committed against BARISONE under color of law, which deprived him of his constitutional rights
     and interest, interfered with his exercise of those rights and interests, and/or were unlawful
     attempts to interfere with those rights and interests, WASHINGTON TOWNSHIP, the
     DEFENDANT POLICE OFFICERS, and/or the other defendants, individually and jointly cause
     BARISONE to suffer injury-in-fact of a concrete, particularized, and actual nature.
141. In addition to any and all direct liability it has based upon the claims and allegations
     set forth above, defendant WASHINGTON TOWNSHIP also has derivative municipal liability
     for the unlawful acts and omissions of the other defendants, based upon defendant
     WASHINGTON TOWNSHIP’s failure to properly monitor, supervise, control and/or train the
     DEFENDANT POLICE OFFICERS and/or other defendants.
142. But for the defendants’ unlawful violations of BARISONE’s civil rights, the
     August 7, 2019 Incident and other incidents would not have occurred, and/or would have occurred
     differently and without injury or harm caused to BARISONE, his business, the Farm, and/or the
     other people at the Farm.
143. As a direct and proximate result of the acts, actions and omissions of the defendants
     which violated BARISONE’s civil rights, BARISONE suffered: (a) economic loss (including lost
     income from his business); (b) damage to his reputation in the community and his professional
     reputation; © emotional distress; (d) harm to his family and personal relationships; (e)
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     consequential damages; (f) injury to his future earnings capacity; (g) loss of his freedom; and (h)
     other injury, damages, and loss including mental anguish, physical discomfort, physical injury and
     harm, pain and suffering, shame and embarrassment and other emotional distress injuries.
     LAD Violations
144. Alternatively, during and throughout the aforementioned protracted, intentional,
     derelict interactions which WASHINGTON TOWNSHIP and the DEFENDANT POLICE
     OFFICERS had with BARISONE and Kanarek, WASHINGTON TOWNSHIP, the
     DEFENDANT POLICE OFFICERS, and/or the other defendants, ignored, dismissed, hid, failed
     to report, failed to acknowledge, failed to take seriously, and/or otherwise rejected, BARISONE
     and/or his reports to them due to BARISONE’s advanced age (he was in his fifties), BARISONE’s
     gender (he was a male reporting stalking and harassment by a female), BARISONE’s status as a
     person who suffered from mental illness, and/or based upon other traits and characteristics
     protected against unlawful discrimination under the New Jersey Law Against Discrimination (the
     “LAD”).
145. At the time of the incidents, BARISONE was a Caucasian male in his 50’s, whereas
     Kanarek was an attractive, blond, Caucasian female in her 30’s.
146. At the time of the incidents, BARISONE was a person suffering from various
     emotional, psychological and/or psychiatric maladies, the presence of which was readily apparent
     to and known by the defendants, individually and collectively, and to others who interacted with
     BARISONE during the incidents.
147. At the time of the incidents, WASHINGTON TOWNSHIP, the DEFENDANT
     POLICE OFFICERS, and/or the other defendants, individually, jointly, and/or severally,
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     committed the wrongful acts, actions and omissions, motivated by unlawful discrimination against
     BARISONE based upon his protected traits, including but not limited to his age, his gender, and/or
     his status as a person suffering from mental disease, maladies, and/or defects (the “unlawful
     discrimination”).
148. As a direct and proximate result of the unlawful discrimination against
     BARISONE, WASHINGTON TOWNSHIP, the DEFENDANT POLICE OFFICERS and the
     other defendants intentionally ignored, dismissed, and/or otherwise rejected BARISONE’s
     complaints, urgings, requests for assistance, requests to speak with police supervisors, “911”
     reports of crime and criminal behaviors.
149. But for the defendants’ unlawful discrimination, the August 7, 2019 Incident and
     other incidents would not have occurred, and/or would have occurred differently and without
     injury or harm caused to BARISONE, his business, the Farm, and/or the other people at the Farm.
150. In addition to any and all direct liability it has based upon the claims and allegations
     set forth above, defendant WASHINGTON TOWNSHIP also has derivative municipal liability
     for the unlawful acts and omissions of the other defendant, based upon defendant WASHINGTON
     TOWNSHIP’s failure to properly monitor, supervise, control and/or train the DEFENDANT
     POLICE OFFICERS and/or other defendants.
151. As a direct and proximate result of the acts and omissions of the defendants which
     constituted violations of the LAD, BARISONE suffered: (a) economic loss (including lost income
     from his business); (b) damage to his reputation in the community and his professional reputation;
     © emotional distress; (d) harm to his family and personal relationships; (e) consequential
     damages; (f) injury to his future earnings capacity; (g) loss of freedom; and (h) other injury,
     MRS-L-001562-21 07/15/2021 1:56:46 PM Pg 33 of 36 Trans ID: LCV20211664981
     34
     damages, and loss including mental anguish, physical discomfort, physical injury and harm, pain
     and suffering, shame and embarrassment and other emotional distress injuries.
     WHEREFORE, Plaintiff demands judgment in his favor, and against each and every
     one of the defendants, jointly and severally, awarding plaintiff the following:
     A. Permanent restraints barring the defendants from committing civil rights violations;
     B. Permanent restraints barring the defendants from perpetrating violations of the New
     Jersey Law Against Discrimination;
     C. Compensatory damages (including loss of business income);
     D. Damages for psychological distress, psychiatric injury, humiliation, mental and
     emotional distress;
     E. Attorneys’ fees and costs of suit;
     F. Lawful interest; and
     G. Such other, further, and different relief as the Court deems just and proper.

[Sdel]

Civil or criminal filing?

[eggbutt]

Only Civil is posted on line for public use.

[Graymaresrule]

Wow

[Knights_Mom]

Oh.

Damn.

[splitrockfarmnc]

Well we all knew there would be two+ sides to this saga.
That was eye-opening, although not totally unexpected.

Interesting.

[Jenerationx]

Hmmm interesting that the police didn’t investigate the recording devices. I also wonder what prevented a co-owner from removing the devices.

There certainly were a lot of 911 calls.

[Knights_Mom]

Oh.

Damn.

[Sdel]

Well, I’ve been going through the “Woman Shot” thread and something jumped out at me…

LK posted a comment on RC’s FB page that basically accused her of lending her gun to MB knowing he was going to murder her in the first sentence and then a few sentences later mocked her for being negligent for “losing” her gun.

Hmmmm…

ETA: Its post 3709 if anyone wants to go looking:

Posted on Ruth Cox’s FB page under a picture of a dog.

Lauren Kanarek In America, it’s forbidden 🚫 by law to knowingly lend your gun to a person to commit two murders. Surely, a nurse with a PH.D would know that. Just bc mB is whispering with you doesn’t mean the forensics lab can’t HEAR YOUR CONVERSATION.
You are not the barn manager. You’d show up once every few months. Also… remember when DD had that throat problem? Remember when you wanted to have a say in the treatment? Do you wonder why I even know about that? I’ll tell ya. MH and MB told the WHOLE BARN you have NO SAY and you think you’re a bully. Michael made sure to let everyone know- HE IS THE BIGGER BULLY. In any case, any barn manager (since that’s the story you’re going with - even though many people from Newbern can account for your whereabouts during ALL the times you were NOT in NJ- making it impossible for you to have been “barn manager,”) is negligent at best for allowing your pink and black 9mm Ruger to just go missing -especially with two 12 yr old children running around- and reckless negligence plus aiding abetting plus conspiracy to commit murder at worst.

[LexInVA]

A lot of this stuff fits with what was previously dug up about her and her whacked-out behavior. The area in which she had been living in NC is an epicenter of drug addiction, with a lot of Cocaine and Heroin being brought into the community and the area in which LK was raised has long been an epicenter of drug addiction, particularly Heroin, which has ravaged the NJ suburbs outside of NYC, and she’s long been away from the family home and living in the South, occasionally coming home and being seen with only the Mom and sisters, who all fancy themselves as high-achieving socialites and not her Father, who probably kicked her out, yet still pays her expenses, likely to keep her away and out of sight, as she clearly did cause some social disgrace back in the day. As for her Father, he definitely is an attorney and has been for over forty years, but he has had no documented history as one and is nothing more than a name and number in the NYC/NJ legal community, so whatever he’s involved in is behind closed doors and apparently involves enough money to finance a high-falutin lifestyle for the women of the household. He’s been involved in social stuff over the years, the sort that makes a local name for one’s self and allows for networking to wheel and deal, but is otherwise completely low-profile since the turn of the century and you’d have trouble finding any recent photograph of him that wasn’t from his appearance in the court room pews, in support of his daughter.

[Jenerationx]

Is “the Barisone” a typo of “to Barisone” or are we now referring to MB as “The Barisone?”

[eggbutt]

I noticed several typos in this document. I cut and pasted it directly from the brief as it appears on line.

[MHM]

Here’s my question.

How is her appearance of any legal relevance? Two different times she’s referred to as an “attractive blond woman.” What does that have to do with anything?

Is the implication that the male (?) police officers were influenced by her looks?

[BigMama1]

It’s disturbing to read, but I didn’t think it reveals anything we didn’t already know from previously released information. Will be interesting to see if the police are held responsible for allegedly failing to do their duty in protecting Barisone.

It is reasonable to assume the childhood trauma and mental distress will be key parts of a mental defect defence at the criminal trial?

[Jenerationx]

@BigMama1

Will be interesting to see if the police are held responsible for allegedly failing to do their duty in protecting Barisone.

I’ll be interested to see if they are as well. I can’t see it. Although they were called many times, unless they actually witness or have hard evidence of a crime, I don’t know what they could have done.

I can say that I’m in fear for my life because my neighbors are weird, but unless I can show a reason the police can see…

[Sdel]

@BigMama1

It’s disturbing to read, but I didn’t think it reveals anything we didn’t already know from previously released information. Will be interesting to see if the police are held responsible for allegedly failing to do their duty in protecting Barisone.

If anything has teeth it will be the accusation that the police knew she was recording them and/or that they were trying to find out where the kids would be when they were with their dad. I assume they pulled a search history to that effect from one of her devices or the wouldn’t have made the claim.

[Sdel]

Anyone else think that it is spooky that we were just discussing the recordings and the criminal nature and a few hours later we have a new court case alleging the police knew about it from LK herself…

[eggbutt]

I read it as lack of complete reporting by the LEOS. It is interesting the EMT reported MB’s mental state in his report but the police seem to have decided against it. It would really concern me that he was not given the opportunity to escalate his concerns to upper level supervisors. That could be an issue for the department.

[Knights_Mom]

Although this is the Civil portion of the case, should it occur before the Criminal portion, if the mental disease or defect sticks successfully and is substantiated by an expert as this complaint states, mental disease or defect becomes a defense no brainer in the Criminal trial MAYBE I would think.

In Criminal cases not guilty assertions due to mental disease or defect happens and if successful allows a defendant to get better and go free.