Updated barisone lawsuit 10/29/21 post 851

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SCROLL TO POST 851 TO READ THE REVISED FILE

This was filed this afternoon amending the suit from last week.

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-1562-21
FIRST AMENDED, CORRECTED
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 onetime 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 coached 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 horses at the Farm during the summer season which covers (essentially) the months of
    April through November, following which (during the winter season) Kanarek would following
    BARISONE to Florida to continue her training.
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 blonde woman in her mid- to late30’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 to 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 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 two (2) incidents of discharging her firearm, out of anger and rage, at other people and/or
    their personal property; an incident of carrying a loaded weapon into a political campaign event
    where she was planning to confront people; and, another incident when Kanarek posted of photo
    of a gun to threaten someone on social media.
26. Unbeknownst the BARISONE, the United States Equestrian Federation and/or the
    U.S. Center for “Safe Sport” (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 cause harm.
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
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    from abuse as a child.
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.
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38. Separate and apart from that temporary “house guest” arrangement, Kanarek was
    again boarding her horse in the barn at the Farm.
39. Soon after she started staying as a house guest at the Farm, Kanarek commenced
    displaying behavior towards BARISONE, Gray, and/or other Farm residents and visitors, 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. For example, on or about July 25, 2019, seeking to threaten and intimate
    BARISONE and Gray, Kanarek posted a ranting message on social media in which she bragged
    about her past stalking and harassment of people, which was reasonably understood by
    BARISONE to be Kanarek threating him, in which Kanarek spoke of “DEATH” in the context of
    those who were in conflict with her.
45. Thereafter, on or about July 31, 2019, Kanarek expressly threatened violence and
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    harm against BARISONE and Gray including Kanarek’s threat that she would “destroy” Gray
    and everything Gray possessed, including Gray’s children, BARISONE, the Farm, and/or their
    horses.
46. It was based upon those threats, other threats and statements made by Kanarek,
    and/or other behaviors by Kanarek and Goodwin, that BARISONE, Gray, and others at the Farm,
    were reasonably placed in fear of physical harm and property destruction by Kanarek and
    Goodwin.
47. 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 of, and
    intentionally 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
48. 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.
49. 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.
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50. 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 and/or wellbeing, and/or the wellbeing of
    their property.
51. 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.
52. For example, during the July 31, 2019 incident, BARISONE’s affect, statements
    and behaviors evidenced outwardly that BARISONE was being psychologically assaulted and
    victimized by Kanarek and Goodwin, such that the police knew of, and intentionally 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.
53. 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”), knowing that the August 1,
    2019 Police Report was materially false and misleading through the statements they made in that
    report and/or the information they omitted from it, and/or in actionable reckless disregard that the
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    report was materially false and/or misleading because of that.
54. 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 and wellbeing, and/or
    the wellbeing of their property; (b) failed to document the report by BARISONE and/or Gray that
    Kanarek had made the terroristic threat to injury Gray, her children and/or her property; 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.
55. The August 1, 2019 Police Report documented as well that the responding
    DEFENDANT POLICE OFFICERS violated police protocol by interviewing Kanarek and
    Goodwin (the alleged criminal perpetrators) before interviewing BARISONE, the “911”
    complainant, evidencing unlawful bias by the defendants against BARISONE and evidencing
    other wrongs.
    The August 1, 2019 Incident
56. The situation continued to escalate out of control, with Kanarek and Goodwin
    increasing their terroristic threats, harassment, stalking, and/or other criminal behaviors, against
    BARISONE, Gray, and other people on the premises of the Farm.
57. For example, on or about the morning of August 1, 2019, Goodwin cornered two
    minors residing at the Farm (students of BARISONE) and attempted to force the minors to agree
    with Goodwin’s assertion that BARISONE was wrong to have call the police against him and
    Kanarek the prior day. The minors resisted Goodwin’s bullying, whereupon Goodwin became
    aggressive toward one of the minors and threatened her physically.
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58. The incident was extremely upsetting to the minor, whereupon she reported it to
    BARISONE and further argument and verbal assault was directed at BARISONE by Kanarek
    and/or Goodwin, following which BARISONE made his second “911” call to the
    WASHINGTON TOWNSHIP POLICE DEPARTMENT seeking emergency assistance.
59. 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.
60. 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.”
61. 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.
62. DEFENDANT HENSLEY and DEFENDANT SEABECK intentionally
    disregarded the facts and circumstances being reported to them and intentionally failed to take
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    appropriate action, choosing instead to avoid their duty to act by falsely characterizing the
    situation as a “private dispute,” a tactic those defendants and the other defendants (in particularly,
    defendant WASHINGTON TOWNSHIP) utilized unlawfully as a practice, custom, and/or policy.
63. For example, during the August 1, 2019 incident, BARISONE’s affect,
    statements, and behaviors evidenced outwardly that BARISONE was being psychologically
    assaulted and victimized by Kanarek and Goodwin, such that the police knew of, and intentionally
    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 dispute.”
64. When the responding DEFENDANT POLICE OFFICER finally made it up to the
    barn where BARISONE, Gray, and the other peaceful visitors/residence had congregated, the
    DEFENDANT POLICE OFFICER were presented with the minor who Goodwin had assaulted.
65. Speaking through a torrent of tears, the minor told the responding DEFENDANT
    POLICE OFFICERS how Goodwin had threatened her physically and placed her in fear for “in
    fear for her life”; whereupon the DEFENDANT POLICE OFFICES asked the minor “Did he
    [Goodwin] threaten to kill you?”
66. Upon hearing the minor’s response, which was “no,” the DEFENDANT POLICE
    OFFICERS turned away from her, stopped listening to her legitimate report of fear and threats,
    and failed to give the minor or her complaint any further audience or meaningful consideration.
67. Upon information and belief, to the responding DEFENDANT POLICE
    OFFICERS and WASHINGTON TOWNSHIP, the defendants would not offer to consideration
    to any type of threat of assault or assault short of one in which Goodwin and/or Kanarek threatened
    expressly to “kill” someone, regardless of what other physical harm or mayhem Kanarek and/or
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    Goodwin might threaten or cause short of killing someone.
68. BARISONE made further reports to the DEFENDANT POLICE OFFICES during
    their “911” visit to the Farm, including reports of stalking, trespass, and unauthorized attempts by
    Kanarek and/or Goodwin to enter the locked club house in the barn.
69. BARISONE reported to the responding DEFENDANT POLICE OFFICERS that
    BARISONE had found discarded boxes of “Suboxone” in the garbage Kanarek and/or Goodwin
    from the farm house, a drug used to treat heroin addiction.
70. But based upon the position they took in response to the minor’s report, the
    defendants intentionally discounted, mischaracterized, and/or simply ignored, BARISONE’s
    reports, in abject violation of applicable laws, rules, statute, policies and procedures (including
    the New Jersey Attorney General guidelines governing police conduct).
71. 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”), knowing that the
    August 2, 2019 Police Report was materially false and misleading through the statements they
    made in that report and/or the information they omitted from it, and/or in actionable reckless
    disregard that the report was materially false and/or misleading because of that.
72. 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; (b) failed to document in any manner the
    responding officers’ interview of the minor who Goodwin had threatened physically, and/or the
    minor’s report to the responding officers that she was in fear for her life and of physical harm
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    from Kanarek and/or Goodwin; 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.
73. In connection with their response 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”).
74. During that call with MCPO, DEFENDANT SEABECK failed intentionally to
    make a full, complete, truthful and/or accurate report of the incidents and evolving situation at the
    Farm, instead choosing intentionally to fail to report to MCPO 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/or wellbeing, and/or to the wellbeing of their property, from physical
    harm threatened by Kanarek and/or Goodwin.
75. 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
    disputes” incidents which, in fact, were criminal in nature.
76. 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.
77. The August 2, 2019 Police Report documented as well that the responding
    DEFENDANT POLICE OFFICERS violated police protocol by interviewing Kanarek and
    Goodwin (the alleged criminal perpetrators) before interviewing BARISONE, the “911”
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    complainant, evidencing unlawful bias by the defendants against BARISONE and evidencing
    other wrongs.
    The August 3, 2019 Incident
78. The situation continued to escalate out of control, with Kanarek and Goodwin
    increasing their terroristic threats, harassment, stalking, and/or other criminal behaviors.
79. The behaviors of Kanarek and Goodwin at the Farm, for example, evidenced what
    others on the premises took to be planning, stalking, and threats to injury Gray’s horse and/or
    other horse boarded in the barn, including the possibility that the barn might be set on fire.
80. But that was hardly the only mayhem Goodwin and Kanarek intentionally caused
    at the Farm now that the WASHINGTON TOWNSHIP and the responding DEFENDANT
    POLICE OFFICERS had empowered those perpetrators through the defendants’ failures and
    refusals to take appropriate action following the first, two “911” calls BARISONE had made.
81. For the purpose of threatening BARISONE and Gray and to cause them fear for
    their lives and the lives of Gray’s children, Kanarek and Goodwin commenced cyber-stalking
    Gray’s children by sending them social media “friend requests” and/or like contacts.
82. The contacts initiated by Kanarek and/or Goodwin were particularly disturbing
    when taken in context, based upon Kanarek’s prior expressed threat of violence and mayhem
    against Gray to “destroy” Gray and everything in Gray’s life that was “important” to Gray,
    following Kanarek’s Internet posting regarding “death” to her enemies.
83. Making matters even more threatening, Kanarek and/or Goodwin continued their
    efforts to trespass into the club room at the barn, where BARISONE, Gray and the other peaceful
    residents at the Farm had taken refuge from Kanarek and Goodwin.

[eggbutt]

PART 2:

84. An even more ominous phenomena was presented by Kanarek and/or Goodwin
    through text messages and statements they made to BARISONE and others, through which
    Kanarek and Goodwin revealed private information concerning BARISONE, Gray, and or others,
    information which could only have obtained through unlawful trespass, unlawful stalking, and/or
    the placement of illegal electronic listening devices in the private living area(s) at the barn.
85. As a result, BARISONE made his third “911” call to the WASHINGTON
    TOWNSHIP POLICE DEPARTMENT seeking emergency assistance.
86. 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.
87. 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.”
88. 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
    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;
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    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.
89. 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 expressly threatened BARSIONE and others to use firearms against
    them through Kanarek’s posting and/or other statements indicating that she was
    coming to get them with “weapons hot,” meaning that she was armed and ready
    to discharge a firearm at 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;
    (e) Kanarek was claiming that she had uncontrollable “multiple personalities”
    through which she would cause harm to BARISONE and others at the Farm;
    and/or,
    (f) Kanarek had a criminal history, history as a drug addict, and other personal
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    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.
90. BARISONE even provided the responding DEFENDANT POLICE OFFICERS
    printouts of examples of Kanarek’s overtly threatening, Interne t postings, and told the
    DEFENDANT POLICE OFFICERS that BARISONE wanted – in fact, insisted – that he get to
    speak with a supervisor, a detective, and/or a mental health professional to deal with the
    developing, dangerous circumstances.
91. 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”).
92. The placement of those devices without consent of the property owner, upon
    information and belief, is criminal trespassing under New Jersey law.
93. The Eavesdropping was unlawful under New Jersey law.
94. Moreover, the disclosure of unlawfully intercepted oral communications is a crime
    under New Jersey law.
95. Nevertheless, the responding DEFENDANT POLICE OFFICERS failed to
    investigate the criminal acts Goodwin has reported to them he and/or Kanarek had committed,
    failed to take other appropriate non-discretionary action in response to notification that such
    criminal conduct was occurring, and intentionally failed to intervene.
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96. 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.”
97. Those POLICE OFFICER DEFENDANTS also disregarded, during the August 3,
    2019 incident, BARISONE’s affect, statements, and behaviors evidenced outwardly that
    BARISONE was being psychologically assaulted and victimized by Kanarek and Goodwin, such
    that the police of, knew and intentionally 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.
98. 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”), knowing that the
    August 8, 2019 Police Report was materially false and misleading through the statements they
    made in that report and/or the information they omitted from it, and/or in actionable reckless
    disregard that the report was materially false and/or misleading because of that.
99. 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 loaded 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
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    occurring at the Farm that day.
100. In connection with their response to BARISONE’s August 3, 2019 “911” call and
     their visit to the Farm, the responding DEFENDANT POLICE OFFICERS finally bothered to
     contact the MCPO but then proceeded to give the MCPO a materially misleading report by, among
     other things, failing to advised the MCPO of the Kanarek-Goodwin statement that they were using
     eavesdropping devices on the premises.
101. 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.
102. Upon information and belief, had the defendants (especially the responding
     DEFENDANT POLICE OFFICERS) acted appropriately in response to BARISONE’s criminal
     complaint and “911” emergency call on August 3, 2019, the defendants would have discovered
     that in the early morning hours on or about August 4, 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 (including the purpose of physically harming those
     children); 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
103. The situation continued to escalate out of control, with Kanarek and/or Goodwin
     increasing their terroristic threats, harassment, stalking, and/or other criminal behaviors, causing
     BARISONE to make his fourth “911” call to the WASHINGTON TOWNSHIP POLICE
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     DEPARTMENT seeking emergency assistance.
104. 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 was escalating, and
     demonstrating that BARISONE and others were in fear of immediate danger and injury to their
     physical health and wellbeing, and/or the wellbeing of their property.
105. 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”
     (i.e., physically harm) Cox should she attempt to intervene – words which reasonably placed
     BARISONE, Cox and others in fear for their lives from violence against them by Kanarek and/or
     Goodwin.
106. 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.
107. Thereafter, DEFENDANT BIGHAM arrived first at the Farm; DEFENDANT
     CONSTANTINO responded later based on his intentional choice to treat BARISONE’s “911”
     emergency call as a “non emergency.”
108. In abject violation of standard police protocol, policy and procedure,
     DEFENDANT BIGMAN interviewed Kanarek and Goodwin before the DEFENDANT POLICE
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     OFFICERS interviewed BARISONE, the criminal complainant who called “911.”
109. 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 and wellbeing, and/or the wellbeing of their property.
110. 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.
111. 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 Sergeant and/or Detective.
     BARISONE’s request, once again, was rejected by the responding DEFENDANT POLICE
     OFFICERS, who said “no.”
112. 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.
113. DEFENDANT COSTANTINO and DEFENDANT BIGHAM intentionally
     disregarded all of those the facts and circumstances being reported to them and intentionally failed
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     to act to intervene on behalf of BARISONE and/or the others making the report to
     WASHINGTON TOWNSHIP against Kanarek and Goodwin.
114. Those POLICE OFFICER DEFENDANTS also disregarded, during the August 4,
     2019 incident, BARISONE’s affect, statements, and behaviors evidenced outwardly that
     BARISONE was being psychologically assaulted and victimized by Kanarek and Goodwin, such
     that the police knew of, and intentionally and/or recklessly disregarded, BARISONE’s mounting
     psychological distress that was about to cause a psychiatric breakdown because appropriate and
     sufficient action was not taken by the defendants to intervene in what obviously was a criminal
     matter, not a private dispute.
115. 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”), knowing that the
     August 4, 2019 Police Report was materially false and misleading through the statements they
     made in that report and/or the information they omitted from it, and/or in actionable reckless
     disregard that the report was materially false and/or misleading because of that.
116. 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
     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.
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117. In connection with their response 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.
118. 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
119. The situation continued to escalate out of control, with Kanarek and/or Goodwin
     increasing their 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 3:
120. Kanarek continued posting threats of death, harm and/or mayhem on social media,
including expressed statements by Kanarek that she had “guns” and “hollow point bullets,”
placing BARISONE, Gray and the other peaceful people at the Farm in fear for their lives once
again.
121. 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.
122. 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
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again advise 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.
123. 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.
124. 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.”
125. 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.
126. 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.
127. The DEFENDANT POLICE OFFICERS, with hands on their belts (indicating that
weapons could be drawn against BARISONE), stood stone-faced, staring at BARISONE, pushing
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out their chests and doing whatever they could to intimidate BARISONE.
128. 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.
129. 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.
130. 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.
131. 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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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.
132. Those POLICE OFFICER DEFENDANTS intentionally disregarded
BARISONE’s affect, statements, and behaviors evidenced outwardly that BARISONE was being
psychologically assaulted and victimized by Kanarek and Goodwin, such that the police knew of,
and intentionally 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
133. 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.
134. 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.
135. 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.
136. 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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137. 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.
138. 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.
139. While BARISONE was speaking to the WASHINGTON TOWNSHIP public
officials in the barn, Goodwin (who was also present to listen in) glared at BARISONE and mouth
the words that BARISONE should “get ready,” which BARISONE understood to mean “get ready
for more mayhem, destruction, injury and harm.”
140. Therefore, at that point in time, the defendants had actual knowledge that the
occurrence at the Farm occurring since July 31, 2019, was not a “private,” “landlord-tenant”
dispute they could sidestep to avoid taking non-discretionary action to intervene.
141. 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.
142. 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.
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143. 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
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.
144. 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 of, and intentionally and/or recklessly disregarded, the fact
that BARISONE was now experiencing profound psychological distress and was in the process
of experiencing a psychiatric breakdown.
145. During this incident, a WASHINGTON TOWNSHIP employee at the Farm on
behalf of the township observed BARISONE’s profound level of psychological and emotional
distress, his uncontrollable shaking and shivering, and his repeated statements that he was “in
fear” for his life.
The August 6, 2019 Evening Incident
146. 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.
147. 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.
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148. 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.
149. BARISONE advised WASHINGTON TOWNSHIP that the township needed to
expel Kanarek and Goodwin from the living spaced in order to comply with the township’s order
to vacate the premises because, as BARISONE, he was in fear for his life.
150. It was following that discussion that WASHINGTON TOWNSHIP officials
sought access to the farm house to enter the area Kanarek and Goodwin were occupying.
151. WASHINGTON TOWNSHIP took Cox to the Farm house to make that entry,
whereupon Cox was viciously attacked and bitten by Kanarek’s violent dog.
152. A WASHINGTON TOWNSHIP ambulance was called to the scene, whereupon
Cox was treated for the dog bite.
153. The WASHINGTON TOWNSHIP police were in attendance as well; they refused
to remove the dog from the premises or even to advise Kanarek that she could not lawfully occupy
the premises.
154. 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
that was occurring due to the defendants’ failure to take appropriate action.
155. The police officers in attendance during this incident, namely DEFENDANT
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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
knowing that the August 11, 2019 police report was materially false and misleading through the
statements they made in that report and/or the information they omitted from it, and/or in
actionable reckless disregard that the report was materially false and/or misleading because of
that.
The August 7, 2019 Incident
156. 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”).
157. BARISONE was indicted for the August 7, 2019 Incident, was charged criminally,
and is presently being held in jail awaiting trial.
158. BARISONE has no recollection of the shooting and has entered a “not guilty” plea.
159. 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.
160. In the aftermath of the August 7, 2019 Incident, WASHINGTON TOWNSHIP
Police assembled people at the Farm, at the time of the shooting (exclude BARISONE, Kanarek,
and/or Goodwin) in the club of the barn and interviewed them as potential witnesses.
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161. In the presence of the people being interviewed, a WASHINGTON TOWNSHIP
Police Officer stated anecdotally, in words, sum and/or substance, that: (a) there are numerous
reports to the Police in WASHINGTON TOWNSHIP of shots fired to which the police respond
or investigate; (b) the high number of such calls was due to the fact that WASHINGTON
TOWNSHIP has people who fire guns while hunting; © when the report came over the radio of
a shooting at the Farm, the officer concluded it was a real shooting, not an incident of shots fired
for the purpose of hunting; and (d) “we had been worried that something like that might happen.”
Other Allegations
162. By the time that the August 7 Incident occurred, Kanarek and/or Goodwin had
made express threats and/or undertaken act of assault, threatening behavior, and harm against no
fewer than seven (7) people at the Farm, namely: BARISONE; Gray; Gray’s two minor children;
the two students Goodwin intimidated; and, Cox.
163. By the time that the August 7 Incident occurred, Kanarek and/or Goodwin had
expressly, directly, and/or indirectly threatened “death”; destruction; using firearms; coming for
people with “weapons hot” loaded firearms; “taking down” whoever might get in the way of their
plan to harm BARISONE and/or Gray; possessing “guns” and “hollow point bullets”; and other
material threats.
164. WASHINGTON TOWNSHIP and the other defendants were advised repeatedly of
that information but, nevertheless, unlawfully chose to disregard it unlawfully
165. 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.
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34
166. 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.
167. 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
168. 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,
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.
169. 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.
170. 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
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35
interfering with and/or attempting to interfere with same, including but 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, and his right to make reports of wrongdoing to senior
members of the WASHINGTON TOWNSHIP Police Department;
© 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;
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36
(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.
171. 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:
(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
from 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;
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37
(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
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.
172. 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 caused
BARISONE to suffer injury-in-fact of a concrete, particularized, and actual nature.
173. 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
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38
WASHINGTON TOWNSHIP’s failure to properly monitor, supervise, control and/or train the
DEFENDANT POLICE OFFICERS and/or other defendants.
174. 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.
175. 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)
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
176. 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
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39
protected against unlawful discrimination under the New Jersey Law Against Discrimination (the
“LAD”).
177. At the time of the incidents, BARISONE was a Caucasian male in his 50’s, whereas
Kanarek was an attractive, blonde, Caucasian female in her 30’s.
178. 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.
179. At the time of the incidents, WASHINGTON TOWNSHIP, the DEFENDANT
POLICE OFFICERS, and/or the other defendants individually, jointly, and/or severally,
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”).
180. 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, and “911”
reports of crime and criminal behaviors.
181. 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.
Intentional Torts
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40
182. Alternatively, at the time of the incidents, WASHINGTON TOWNSHIP, the
DEFENDANT POLICE OFFICERS, and/or the other defendants individually, jointly, and/or
severally, committed the wrongful acts, actions and omissions, which constituted intentional torts
against BARISONE, including acts of official misconduct, criminal civil right deprivations, and/or
other wrongful conduct not subject to tort immunity.
183. 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.
184. 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,
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);
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41
D. Damages for psychological distress, psychiatric injury, humiliation, and 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.
DEININGER & ASSOCIATES, LLP
Attorneys for Plaintiff
By : ____________________________________
CHRISTOPHER L. DEININGER, ESQ.
Dated: July 22, 2021
JURY DEMAND
Plaintiff demands a trial by jury as to all issues.
DEININGER & ASSOCIATES, LLP
Attorneys for Plaintiff
By : ____________________________________
CHRISTOPHER L. DEININGER, ESQ.
Dated: July 22, 2021
CERTIFICATION PURSUANT TO RULE 4:5-1
The undersigned, Christopher L. Deininger, Esq., certifies on behalf of the Plaintiff as
follows:

1. I am an attorney admitted to practice law in the State of New Jersey,
   counselfor the above-named Plaintiff in the subject action.
   MRS-L-001562-21 07/22/2021 2:30:26 PM Pg 41 of 42 Trans ID: LCV20211721448
   42
2. The matter in controversy in this case is not, to my knowledge, the
   subject of any other action pending in any Court or pending arbitration proceeding, nor
   is any other action or arbitration proceeding contemplated, although there are other
   criminal and civil matters arising from the August 7, 2019 Incident.
3. There are no other parties who should be joined in this action that we are
   aware of at the present time, although plaintiff has named fictitious parties which could
   result on the subsequent addition of other parties.
   I hereby certify that the foregoing statements made by me are true. I am aware that
   if any of the foregoing statements made by me are willfully false, I am subject to
   punishment.
   DEININGER & ASSOCIATES, LLP
   Attorneys for Plaintiff
   By : ____________________________________
   CHRISTOPHER L. DEININGER, ESQ.
   Dated: July 22, 2021
   CERTIFICATION UNDER R. 4:5-1(b)(3)
   I certify that confidential personal identifying information has been removed from the
   documents now submitted to the Court, and will be redacted from all documents submitted in the
   future in accordance with R. 1:38-7(b).
   DEININGER & ASSOCIATES, LLP
   Attorneys for Plaintiff
   By: _______________________________
   Christopher L. Deininger, Esq

[ASB_Stars]

Why did you post this up here? You do know the definition of insanity, right?

[Angela_Freda]

@eggbutt

25
Unbeknownst to BARISONE, Kanarek’s past included owning firearms and at
least two (2) incidents of discharging her firearm, out of anger and rage, at other people and/or
their personal property; an incident of carrying a loaded weapon into a political campaign event
where she was planning to confront people; and, another incident when Kanarek posted of photo
of a gun to threaten someone on social media

44

1. For example, on or about July 25, 2019, seeking to threaten and intimate
   BARISONE and Gray, Kanarek posted a ranting message on social media in which she bragged
   about her past stalking and harassment of people, which was reasonably understood by
   BARISONE to be Kanarek threating him, in which Kanarek spoke of “DEATH” in the context of
   those who were in conflict with her.
2. Thereafter, on or about July 31, 2019, Kanarek expressly threatened violence and
   MRS-L-001562-21 07/22/2021 2:30:26 PM Pg 8 of 42 Trans ID: LCV20211721448
   9
   harm against BARISONE and Gray including Kanarek’s threat that she would “destroy” Gray
   and everything Gray possessed, including Gray’s children, BARISONE, the Farm, and/or their
   horses.

57

1. For example, on or about the morning of August 1, 2019, Goodwin cornered two
   minors residing at the Farm (students of BARISONE) and attempted to force the minors to agree
   with Goodwin’s assertion that BARISONE was wrong to have call the police against him and
   Kanarek the prior day. The minors resisted Goodwin’s bullying, whereupon Goodwin became
   aggressive toward one of the minors and threatened her physically.
   MRS-L-001562-21 07/22/2021 2:30:26 PM Pg 11 of 42 Trans ID: LCV20211721448
   12
2. The incident was extremely upsetting to the minor, whereupon she reported it to
   BARISONE and further argument and verbal assault was directed at BARISONE by Kanarek
   and/or Goodwin, following which BARISONE made his second “911” call to the
   WASHINGTON TOWNSHIP POLICE DEPARTMENT seeking emergency assistance.

65

1. Speaking through a torrent of tears, the minor told the responding DEFENDANT
   POLICE OFFICERS how Goodwin had threatened her physically and placed her in fear for “in
   fear for her life”; whereupon the DEFENDANT POLICE OFFICES asked the minor “Did he
   [Goodwin] threaten to kill you?”
2. Upon hearing the minor’s response, which was “no,” the DEFENDANT POLICE
   OFFICERS turned away from her, stopped listening to her legitimate report of fear and threats,
   and failed to give the minor or her complaint any further audience or meaningful consideration.
3. Upon information and belief, to the responding DEFENDANT POLICE
   OFFICERS and WASHINGTON TOWNSHIP, the defendants would not offer to consideration
   to any type of threat of assault or assault short of one in which Goodwin and/or Kanarek threatened
   expressly to “kill” someone, regardless of what other physical harm or mayhem Kanarek and/or
   MRS-L-001562-21 07/22/2021 2:30:26 PM Pg 13 of 42 Trans ID: LCV20211721448

Whoa!
If this bit is in this suit, is it already verified by the practice with supporting evidence?

So, they amend these tangled messes by adding new info as it comes to light and is applicable to the case… Without denoting those new portions? That’s Efficient.

Re 57, shouldn’t Safe Sport be apprised of this?

[eggbutt]

Keep reading.

[eggbutt]

Because others who don’t have access to CE asked me to. I think it is important as many people interested in this have access to the brief.

We need to try harder at ignoring other posters trying to de-rail the thread. Ignore really does work.

[eggbutt]

It is important to remember if this attorney is quoting dates and direct social media comments, they have copies of those comments.

[Mersidoats]

@eggbutt

Unbeknownst to BARISONE, Kanarek’s past included owning firearms and at
least two (2) incidents of discharging her firearm, out of anger and rage, at other people and/or
their personal property; an incident of carrying a loaded weapon into a political campaign event
where she was planning to confront people; and, another incident when Kanarek posted of photo
of a gun to threaten someone on social media.

@eggbutt

• For example, on or about the morning of August 1, 2019, Goodwin cornered two
  minors residing at the Farm (students of BARISONE) and attempted to force the minors to agree
  with Goodwin’s assertion that BARISONE was wrong to have call the police against him and
  Kanarek the prior day. The minors resisted Goodwin’s bullying, whereupon Goodwin became
  aggressive toward one of the minors and threatened her physically.
  MRS-L-001562-21 07/22/2021 2:30:26 PM Pg 11 of 42 Trans ID: LCV20211721448
  12
• The incident was extremely upsetting to the minor, whereupon she reported it to
  BARISONE and further argument and verbal assault was directed at BARISONE by Kanarek
  and/or Goodwin, following which BARISONE made his second “911” call to the
  WASHINGTON TOWNSHIP POLICE DEPARTMENT seeking emergency assistance

@eggbutt

• When the responding DEFENDANT POLICE OFFICER finally made it up to the
  barn where BARISONE, Gray, and the other peaceful visitors/residence had congregated, the
  DEFENDANT POLICE OFFICER were presented with the minor who Goodwin had assaulted.
• Speaking through a torrent of tears, the minor told the responding DEFENDANT
  POLICE OFFICERS how Goodwin had threatened her physically and placed her in fear for “in
  fear for her life”; whereupon the DEFENDANT POLICE OFFICES asked the minor “Did he
  [Goodwin] threaten to kill you?”
• Upon hearing the minor’s response, which was “no,” the DEFENDANT POLICE
  OFFICERS turned away from her, stopped listening to her legitimate report of fear and threats,
  and failed to give the minor or her complaint any further audience or meaningful consideration.

@eggbutt

• BARISONE reported to the responding DEFENDANT POLICE OFFICERS that
  BARISONE had found discarded boxes of “Suboxone” in the garbage Kanarek and/or Goodwin
  from the farm house, a drug used to treat heroin addiction.
• But based upon the position they took in response to the minor’s report, the
  defendants intentionally discounted, mischaracterized, and/or simply ignored, BARISONE’s
  reports, in abject violation of applicable laws, rules, statute, policies and procedures (including
  the New Jersey Attorney General guidelines governing police conduct).

@eggbutt

• The situation continued to escalate out of control, with Kanarek and Goodwin
  increasing their terroristic threats, harassment, stalking, and/or other criminal behaviors.
• The behaviors of Kanarek and Goodwin at the Farm, for example, evidenced what
  others on the premises took to be planning, stalking, and threats to injury Gray’s horse and/or
  other horse boarded in the barn, including the possibility that the barn might be set on fire.

@eggbutt

• For the purpose of threatening BARISONE and Gray and to cause them fear for
  their lives and the lives of Gray’s children, Kanarek and Goodwin commenced cyber-stalking
  Gray’s children by sending them social media “friend requests” and/or like contacts.
• The contacts initiated by Kanarek and/or Goodwin were particularly disturbing
  when taken in context, based upon Kanarek’s prior expressed threat of violence and mayhem
  against Gray to “destroy” Gray and everything in Gray’s life that was “important” to Gray,
  following Kanarek’s Internet posting regarding “death” to her enemies.

@eggbutt

• 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”).
• The placement of those devices without consent of the property owner, upon
  information and belief, is criminal trespassing under New Jersey law.
• The Eavesdropping was unlawful under New Jersey law.
• Moreover, the disclosure of unlawfully intercepted oral communications is a crime
  under New Jersey law.

Oh. My.

[MHM]

Could someone with a bit of experience wading through this kind of thing please give a brief summary of what is different in the new version?

[MorganSercu]

68. BARISONE made further reports to the DEFENDANT POLICE OFFICES during
    their “911” visit to the Farm, including reports of stalking, trespass, and unauthorized attempts by
    Kanarek and/or Goodwin to enter the locked club house in the barn.
69. BARISONE reported to the responding DEFENDANT POLICE OFFICERS that
    BARISONE had found discarded boxes of “Suboxone” in the garbage Kanarek and/or Goodwin
    from the farm house, a drug used to treat heroin addiction.

Excuse me - BOXES of a controlled substance?

In addition to the additional points - BOXES of suboxone would be a problem in my state. This is not the case in New Jersey?

[MorganSercu]

More specific allegations about how Lauren Kanarek and Robert Goodwin threatened minors. Not just MH’s children.

Also there were boxes of suboxone in Kanarek/Goodwin’s trash. Not just individual empty packets. At the very least it means someone had a big problem with an illegal drug.

[Sdel]

Says she texted them quotes from their private conversations.

[Angela_Freda]

Re the responding Police officers questioning the minor that Goodwin threatened…
Was that kids parents or legal guardian present, and if not, why not?

[trubandloki]

It says a lot about them (more than one them) that they would threaten children and that they would not listen to a child while they tell their version of being threatened. How sad for both people/groups that they showed kids this side of the world, that people are evil and that people do not care that they were threatened.
Sigh!

[Angela_Freda]

I know nothing about Safe Sport, but …

IF Kanarek was present when Goodwin threatened that minor, or IF LK heard it via her surveillance/eavesdropping… And IF LK did nothing but in effect condone it…

[Brown_Derby]

@MorganSercu

Also there were boxes of suboxone in Kanarek/Goodwin’s trash. Not just individual empty packets. At the very least it means someone had a big problem with an illegal drug.

It’s also a very popular street drug known as Bupe or Sobo. Provides a quick high. And highly addictive.

[eggbutt]

There really is simply too many new things to boil it down. You really need to at least skim it if you want the real shock.

[MHM]

@trubandloki

It says a lot about them (more than one them) that they would threaten children and that they would not listen to a child while they tell their version of being threatened.

True that.

Even if the police were sick of sorting through the volleys of 911 calls from the adults, the minors should have gotten more attention.

[YankeeDuchess]

While there are added specific allegations against LK and RG, to me the interesting revision is the new point #149.

There were two living spaces in the farm house. I saw nothing in either version of this filing that said that the building inspectors ordered the whole farmhouse (both living spaces) vacated.

It is conceivable and consistent with everything stated in the filing that the building inspectors ordered the living space that was occupied by Barisone vacated, but not the “living space” that LK was occupying. But I have no way to know whether one or both living spaces were ordered vacated. It is not clear from the lawyerly way in thick the filing is written.

In point #149, it says that Barisone requested that the building inspector order LK and RG to vacate, but whether that was deemed necessary by the building inspector would depend on whether the inspector had condemned just one or both “living spaces”.