PASHMAN STEIN WALDER HAYDEN A Professional ......PASHMAN STEIN WALDER HAYDEN A Professional Corporation Court Plaza South 21 Main Street, Suite 200 Hackensack, NJ 07601 Ph: (201) 270-4930

PASHMAN STEIN WALDER HAYDEN A Professional Corporation Court Plaza South 21 Main Street, Suite 200 Hackensack, NJ 07601 Ph: (201) 270-4930 F: (201) 488-5556 [email protected] CJ GRIFFIN (#031422009) Attorneys for Plaintiff, Digital First Media DIGITAL FIRST MEDIA, Plaintiff, v. CITY OF TRENTON and DWAYNE M. HARRIS, in his official capacity as Records Custodian for the City of Trenton, Defendants.

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SUPERIOR COURT OF NEW JERSEY LAW DIVISION: MERCER COUNTY DOCKET NO.:

Civil Action

VERIFIED COMPLAINT

Plaintiff Digital First Media, through its undersigned counsel, Pashman Stein Walder

Hayden, A Professional Corporation, complains against Defendants City of Trenton and Dwayne

M. Harris (collectively, “Defendants” or “Trenton”)) as follows:

INTRODUCTION

1. This is an action alleging violation of the New Jersey Open Public Records Act

(OPRA), N.J.S.A. 47:1A-1 to -13, and the common law right of access.

2. The records at issue relate to the death of a man that occurred in early April 2020

after officers from the Trenton Police Department used force against him while attempting to

arrest him. The man stopped breathing almost immediately after the encounter. It is not known

whether the use of force was the cause of the death.

MER-L-000856-20 05/01/2020 4:02:28 PM Pg 1 of 30 Trans ID: LCV2020808120

2

3. Videos of the incident were posted on social media by a bystander, who believed

the police acted wrongly and encouraged people to share the video widely. The videos show

Trenton police officers chasing the man around a parking lot and then using force against him as

he tried to escape arrest. The police are then seen performing chest compressions on the man,

after he evidently stopped breathing.

4. Plaintiff files this lawsuit to gain access to records that would shed further light

about what occurred during the incident and reveal the identity of the officers involved,

including the use of force reports and body-worn camera videos.

PARTIES

5. Plaintiff Digital First Media is a media corporation which owns The Trentonian, a

newspaper with headquarters located at 600 Perry Street, Trenton, New Jersey 08618.

6. Defendant City of Trenton (“Trenton”) is a public agency formed under the laws

of New Jersey, with its primary place of business at 319 East State Street, Trenton, New Jersey

08608.

7. Defendant Dwayne M. Harris is the Municipal Clerk and Records Custodian for

Defendant Trenton. The Custodian maintains an office at 319 East State Street, Trenton, New

Jersey 08608. He is being sued in his professional capacity only.

8. Trenton is a “political subdivision of the State” and “ma[kes], maintain[s] or

ke[eps] on file,” or “receive[s] in the course of . . . its official business” government records, and

is thereby subject to OPRA.

VENUE & JURISDICTION

9. Venue is properly laid in Mercer County because Defendant Trenton is located in

Mercer County and because the cause of action arose in Mercer County. R. 4:3-2(a).


3

10. This Court has subject matter jurisdiction pursuant to N.J.S.A. 47:1A-6.

FACTUAL ALLEGATIONS

A. Background Information

11. The Trentonian is an award-winning daily newspaper serving Trenton and the

surrounding Mercer County area. Founded in 1945, The Trentonian covers a broad array of

news, including reporting on area crime, motor vehicle accidents, the operations of State, county,

and local government, and the conduct of elected officials and police officers.

12. Isaac Avilucea is a reporter for The Trentonian who covers local news within

Trenton. Avilucea has won numerous awards and accolades, including twice winning the New

Jersey Society of Professional Journalists’ “Courage Under Fire” Award.

13. On April 3, 2020, officers from the Trenton Police Department responded to a call

reporting that there was a man with his shirt off outside St. Francis Hospital, allegedly shouting

and throwing objects at passing cars. See Exhibit A, a true and accurate copy of an April 3, 2020

news article published by The Trentonian.

14. According to the Trenton Police Department, the man took off running into the

hospital’s parking lot, where he passed out while being taken into custody. He was transported to

the hospital, but he had no pulse and doctors were unable to resuscitate him. See Exhibit A.

15. On April 4, 2020, The Trentonian published an article by Avilucea reporting that

a bystander had posted videos of the incident on social media. The videos, one of which The

Trentonian posted on its website and can be viewed at https://bit.ly/3bR1eaq, depict the man

being “pummeled in the face and sat on while he lay prone on the ground, his head in the dirt, as

officers restrained his hands behind his back.” The videos also “showed officers pumping the

man's chest while performing CPR on him in the parking lot of St. Francis Medical Center.” See


4

Exhibit B, a true and accurate copy of the April 4, 2020 news article published by The

Trentonian.

16. The April 4, 2020 article described the incident in detail from the perspective of

the bystander’s camera:

In one of the videos, the man can be seen running through the parking lot before he's cornered by an officer near a fence. The officer ordered the man to the ground. The man showed his hands, like he was going to give himself up, before shouting for help and running around the officer, according to the video. Then the video, which appeared to be edited, cut to the man on all fours, as a cop placed his hand around the back of the man's neck and pushed down on his head. Another officer arrived and maced the man in the face while he was on his hands and knees screaming for help. The man bear-crawled away from the three officers, who quickly swarmed, smothered and wrestled him to the ground, the videos show. One of the officers repeatedly struck the man in the face while he was face-down on his belly on the ground as officers struggled with him. The man's arms appeared to be behind him when he was struck, and another cop leaned over his legs, according to the video. As officers huddled around the man, one cop continued pressing a knee on the man’s body while he was handcuffed and prone on the ground, his face resting in the dirt. [See Exhibit B.]

17. Few details have been released about the incident so all that is known are what is

seen on the bystander’s videos.

18. The name of the decedent and the police officers who were involved in the

incident have not been disclosed.


5

B. Plaintiff’s OPRA Request

19. To further its reporting into this matter, Plaintiff, through Avilucea, submitted a

records request to Trenton on April 6, 2020 seeking the following records pursuant to OPRA and

the common law right of access:

All body camera footage from the April 3 encounter Trenton Police had with a man in crisis outside of St. Francis Medical Center. All use of force reports filled out by officers involved in the arrest CAD reports Incident[] [Reports] for same 911 call or another other call for the same Dash cam and police radio transmissions for the same Identity of the man who died for same [See Exhibit C, a true and accurate copy of Plaintiff’s April 6, 2020 OPRA request].

20. On April 8, 2020, Trenton’s custodian responded to Plaintiff’s OPRA request and

simply wrote “Denial.” See Exhibit D, a true and accurate copy of Trenton’s April 8, 2020

OPRA response email.

21. Shortly thereafter, Avilucea responded to the custodian and stated: “No reason

was given for the denial of my OPRA request for body camera footage and other relevant

materials as it relates to man who died in police custody outside of St. Francis. Can you please

provide clarity on that?” See Exhibit E, a true and accurate copy of Avilucea’s April 8, 2020

email.

22. On the evening of April 8, 2020, the custodian wrote back to Avilucea and stated:

“I apologize. I have to get Ms. Lee back into the swing of things after an extended absence. That


6

incident is still being investigated by the Police and they are not yet able to release that footage.”

See Exhibit F, a true and accurate copy of the custodian’s April 8, 2020 email.

23. To date, Trenton has not released any records or information responsive to

Plaintiff’s records request.

24. Plaintiff files this lawsuit to gain access to the responsive records pursuant to

OPRA and the common law right of access so that it may continue its reporting.

FIRST COUNT (Violation of OPRA)

25. Plaintiff repeats and incorporates by reference the allegations set forth in the

preceding paragraphs as though fully set forth at length herein.

26. In this state, all government records must be “readily accessible” to the citizens of

this State unless exempted by law. N.J.S.A. 47:1A-1.

27. Plaintiff’s records request sought “government records” as that term is defined by

OPRA because they are documents, videos, and information “made, maintained or kept on file in

the course of [Trenton’s] official business.” N.J.S.A. 47:1A-1.1.

28. The responsive records are not subject to any exemption and should have been

released to Plaintiff within seven business days pursuant to N.J.S.A. 47:1A-5(i).

29. OPRA’s ongoing investigation exemption, N.J.S.A. 47:1A-3(a), exempts records

from access where 1) they were created after an investigation began; 2) there is an ongoing

investigation; and 3) release would be inimical to the public interest.

30. Any responsive 9-1-1 call or other audio that resulted in the police responding to

the scene cannot be subject to the ongoing investigation exemption because it would have been

made prior to the commencement of an investigation. Moreover, it would not be inimical to the

public interest to release the recordings of the call(s). Serrano v. S. Brunswick Twp., 358 N.J.


7

Super. 352, 364 (App. Div. 2003); Courier News v. Hunterdon Cnty. Prosecutor's Office, 358

N.J. Super. 373, 381 (App. Div. 2003).

31. Use of force reports, which are police administrative forms that track whenever

force is used against a suspect, are not the types of documents that may be withheld pursuant to

the ongoing investigation because they do not contain any information that would be inimical to

the public interest if released. In fact, the public’s interest is in disclosure of use of force report

forms so that it may properly monitor police conduct and ensure that police use force only when

appropriate.

32. Release of the body-worn camera footage would not be inimical to the public

interest as it would shed further light upon an incident that resulted in the death of someone in

police custody. Therefore, the ongoing investigation exemption cannot apply.

33. N.J.S.A. 47:1A-3(b) imposes an obligation upon the police to release details about

criminal investigations within 24 hours of a request, including the name of any person who was

arrested and the names of the investigating and arresting law enforcement personnel. Our courts

have construed this to require disclosure of such information where a person dies during what

would have otherwise been an arrest. Despite this obligation, Trenton has not released the name

of the decedent or the names of the officers involved in the incident.

34. Accordingly, Defendants have violated OPRA by:

a) Failing to provide a lawful basis for denying access to government records in

violation of N.J.S.A. 47:1A-5(g);

b) Failing to disclose nonexempt government records or nonexempt portions of

government records, in violation of N.J.S.A. 47:1A-5(g);


8

c) Failing to base a denial of access upon a basis “authorized by law” in violation of

N.J.S.A. 47:1A-6; and

d) Failing to disclosure information required by N.J.S.A. 47:1A-3(b).

WHEREFORE, Plaintiff demands judgment against Defendants:

a. Declaring said actions of Defendants to be in violation of OPRA, N.J.S.A. 47:1A-

1 et seq., failing to provide access to the requested records and information;

b. Directing Defendants to release the requested records and information to Plaintiff

forthwith. Alternatively, if the Court believes that any information is exempt from

public access, Plaintiff respectfully asks the Court to review the records in camera

and then order Defendants to release the records in redacted format and to submit

a certification setting forth a lawful basis for the redactions;

c. Ordering Defendants to preserve the requested records pending resolution of these

proceedings or as otherwise required by law;

d. Awarding counsel fees and costs pursuant to N.J.S.A. 47:1A-6; and

e. For such other relief as the Court may deem just and equitable.

SECOND COUNT (Common Law Right of Access)

35. Plaintiff repeats and incorporates by reference the allegations set forth in the

preceding paragraphs as though fully set forth at length herein.

36. The records at issue relate to the conduct of police officers and an incident

involving a man who died while in police custody, immediately after a use of force.

37. Plaintiff has a compelling interest in reviewing the responsive records to

determine whether the police officers behaved appropriately.


9

38. Our courts have held that dash camera videos in particular should be released

pursuant to the common law right of access.

39. Plaintiff is the “eyes and ears of the public” and intends to continue its reporting

to keep the public informed about this incident.

40. Plaintiff’s interest in the records outweighs Defendants’ interests in secrecy.

41. Accordingly, Defendants’ failure to disclose the requested records violated

Plaintiff’s common law right of access to public records.

WHEREFORE, Plaintiff demands judgment:

a. Declaring said actions of Defendants to be unlawful and invalid;

b. Directing Defendants to release the requested records to Plaintiff

forthwith. Alternatively, if the Court believes that any information is exempt

from public access, Plaintiff respectfully asks the Court to review the documents

in camera and then require Defendants to delete or excise from the records the

portion(s) which are exempt from public access and promptly permit access to the

remainder of the record;

c. Ordering Defendants to preserve the requested records pending resolution of these

proceedings or as otherwise required by law;

d. Awarding attorney fees and costs of suit; and

e. For such other relief as the Court may deem just and equitable.

PASHMAN STEIN WALDER HAYDEN A Professional Corporation, Attorneys for Plaintiff, Digital First Media

Dated: May 1, 2020 By: /s CJ Griffin

CJ GRIFFIN


10

CERTIFICATION PURSUANT TO R. 4:5-1

Plaintiff hereby certifies that the matter in controversy is not the subject of any other

action pending in any Court and is likewise not the subject of any pending arbitration

proceeding. Plaintiff further certifies that it has no knowledge of any contemplated action or

arbitration proceeding regarding the subject matter of this action and that Plaintiff is not aware of

any other parties who should be joined in this action.

PASHMAN STEIN WALDER HAYDEN A Professional Corporation, Attorneys for Plaintiff, Digital First Media

Dated: May 1, 2020 By: /s CJ Griffin

CJ GRIFFIN


VERIFICATION

Isaac Avilucea, of full age, deposes and says:

1. I am a reporter for The Trentonian, the Plaintiff in this matter.

2. I have read the Verified Complaint. The factual allegations of the Verified

Complaint are true. The said Verified Complaint is based on personal knowledge and is made in

truth and good faith and without collusion, for the causes set forth herein. As to any facts alleged

to be upon information and belief, I believe those facts to be true.

3. All documents attached to the Verified Complaint and Brief are true copies and

have not been redacted, changed, modified, adjusted or otherwise altered in any manner by me or

my agents unless so stated.

I certify that the foregoing statements made by me are true. I am aware that if any of the

foregoing statements made by me are willfully false, I am subject to punishment.

________________________________ ISAAC AVILUCEA

Dated: May 1, 2020

11


EXHIBIT A


4/28/2020 'This is really a sad video' expert says of footage of dead man struck, leaned on during encounter with Trenton Police outside hospital | N…

https://www.trentonian.com/news/this-is-really-a-sad-video-expert-says-of-footage-of-dead-man-struck-leaned/article_87748506-768e-11ea-b241-1b7… 1/7

https://www.trentonian.com/news/this-is-really-a-sad-video-expert-says-of-footage-of-dead-man-struck-leaned/article_87748506-768e-11ea-b241-1b7a63a48313.html

FEATURED

'This is really a sad video' expert says of footage of deadman struck, leaned on during encounter with TrentonPolice outside hospital

By Isaac Avilucea [email protected] @IsaacAvilucea on TwitterApr 4, 2020

St. Francis Medical Center

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https://www.trentonian.com/users/profile/Isaac%20Avilucea



TRENTON — An emotionally disturbed man who died during an encounter Friday with Trenton

Police was pummeled in the face and sat on while he lay prone on the ground, his head in the dirt,

as officers restrained his hands behind his back, videos show.

Footage taken by a bystander from across the street also showed officers pumping the man's

chest while performing CPR on him in the parking lot of St. Francis Medical Center. He was

pronounced dead shortly thereafter at the hospital.

The name and age of the man, who was white and appeared middle aged, hasn't been released by

authorities.

His death is being investigated by the state Attorney General's Office of Public Integrity and

Accountability and the New Jersey State Police Homicide Unit, which are required by law to

investigate when a person dies during an encounter with cops or while in custody.

Rich Rivera, a former cop and police accountability expert, felt after reviewing the videos that the

officers mishandled the arrest.

He said they should have done more to deescalate the situation rather than turning to force.

“This is a really a sad video,” he said. “I see the guy, running into the corner like a trapped rat, with

no shirt on. It’s evident this man is having a mental breakdown, a crisis, by his body language. That

sends up a red flag. They should have been doing some intervention and not escalating the

situation. It should have never got to that point.”

The man became incapacitated and flat-lined while getting handcuffed around 12 p.m. after cops

were called because he reportedly took off his shirt and shouted at and threw stuff at passing

vehicles, Trenton Police Lt. Jason Kmiec told The Trentonian.

The man took off running into a parking lot of St. Francis Medical Center, where he passed out

while being restrained as cops attempted to take him into crisis.

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https://www.trentonian.com/news/man-dies-while-being-taken-into-custody-in-trenton-following-foot-chase/article_1aecda38-75de-11ea-bb3f-cbc4717ff6fd.html



He was taken to the hospital, but he didn't have a pulse, and doctors were unable to save him, the

police spokesman said.

The videos, posted on Facebook and YouTube pages belonging to Juan Morales, depicted a more

complete picture of the police response.

In one of the videos, the man can be seen running through the parking lot before he's cornered by

an officer near a fence.

The officer ordered the man to the ground. The man showed his hands, like he was going to give

himself up, before shouting for help and running around the officer, according to the video.

Then the video, which appeared to be edited, cut to the man on all fours, as a cop placed his hand

around the back of the man's neck and pushed down on his head.

Another officer arrived and maced the man in the face while he was on his hands and knees

screaming for help. The man bear-crawled away from the three officers, who quickly swarmed,

smothered and wrestled him to the ground, the videos show.




One of the officers repeatedly struck the man in the face while he was face-down on his belly on

the ground as officers struggled with him. The man's arms appeared to be behind him when he

was struck, and another cop leaned over his legs, according to the video.

As officers huddled around the man, one cop continued pressing a knee on the man’s body while

he was handcuffed and prone on the ground, his face resting in the dirt.

Rivera said the cops should have taken a different tack once they realized the man was in crisis.

“You gotta slow it down,” he said. “Time is on your side. I’m trying to look at this globally. It’s not

rush in and put my life in danger. Let me run after him. You need to be mindful of all this stuff,

and I’m talking real time. And that’s not what this video demonstrates.”

The names of the officers who were involved in the arrest or used force have not been disclosed

by authorities. Many Trenton Police officers are equipped with body cameras, which may have

captured the incident.

Any officer who used force during the man's arrest is required to fill out use-of-force reports.

The AG's office will likely review video surveillance, police reports and other evidence to determine

whether the officers' force was justified.

Without an autopsy, Rivera said it’s hard to know what caused the man’s death. But he said

officers are trained to understand that their “body weight could obstruct an airway or cause chest

compression.”

After officers had the man cuffed and under control, they should have sat him up, Rivera said,

adding the man’s death could have “absolutely been avoided.”

The police accountability expert has little faith the public will get the full story from the AG’s Office.

“They leave them completely in the dark,” he said. “The public never finds out what happens in

these situations. That’s why we keep living through these tragedies because we can’t learn from

them.”

Morales, known by the street name "Pito," was quick to criticize the police's actions in a Facebook

video, absent a determination by authorities.




"They killed that man. Please do me a favor and share that video. Tag the mayor, the governor. Tag

the f**kin' feds," said Pito, who has likely made enemies in the department over inflammatory

posts accusing city cops of misconduct.

Morales was arrested last month after police allegedly caught him with crack cocaine.

A spokesman from the AG's Office said the agency wouldn't release additional information about

the encounter at this time.

Trenton New Jersey Police department brutally attacks and kills man in hospital parking lotApr 4, 2020

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EXHIBIT B


4/29/2020 Man dies while being taken into custody in Trenton following foot chase | News | trentonian.com

https://www.trentonian.com/news/man-dies-while-being-taken-into-custody-in-trenton-following-foot-chase/article_1aecda38-75de-11ea-bb3f-cbc4717f… 1/2

https://www.trentonian.com/news/man-dies-while-being-taken-into-custody-in-trenton-following-foot-chase/article_1aecda38-75de-11ea-bb3f-cbc4717ff6fd.html

FEATURED

Man dies while being taken into custody in Trentonfollowing foot chase

By Isaac Avilucea [email protected] @IsaacAvilucea on TwitterApr 3, 2020

St. Francis Medical Center

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4/29/2020 Man dies while being taken into custody in Trenton following foot chase | News | trentonian.com

https://www.trentonian.com/news/man-dies-while-being-taken-into-custody-in-trenton-following-foot-chase/article_1aecda38-75de-11ea-bb3f-cbc4717f… 2/2

Isaac Avilucea@IsaacAvilucea on Twitter

Isaac Avilucea is The Trentonian’s main municipal scribe. A two-time prior restraint winner and testicular cancersurvivor, he relishes his reputation as the "Mean Girls" reporter that followed his 18-day stay at the now-defunctNorth Adams Transcript.

TRENTON — A man died while being taken into police custody Friday afternoon, outside a city

hospital, authorities said.

The man became incapacitated and flat-lined while getting handcuffed around 12 p.m. after cops

were called because he reportedly took off his shirt and was shouted at and threw stuff at passing

vehicles, Trenton Police Lt. Jason Kmiec said.

The man took off running into a parking lot of St. Francis Medical Center, where he passed out

while being taken into crisis.

He was transported to the nearby hospital, but he didn't have a pulse, and doctors were unable to

save the man, the police spokesman said.

He hasn't been identified, and New Jersey State Police is investigating his death, Kmiec said.

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EXHIBIT C


From: Isaac Avilucea <[email protected]> Date: Mon, Apr 6, 2020 at 12:36 PM Subject: OPRA To: Dwayne M. Harris <[email protected]>

Dear Mr. Harris: Please accept this request under the Open Public Records Act (OPRA), N.J.S.A 47-1A-1 et seq., and the common law right of access for copies, either in paper or electronic form, of the following: All body camera footage from the April 3 encounter Trenton Police had with a man in crisis outside of St. Francis Medical Center. All use of force reports filled out by officers involved in the arrest CAD reports Incidents for same 911 call or another other call for the same Dash cam and police radio transmissions for the same Identity of the man who died for same -- Isaac Avilucea Reporter The Trentonian Office: 267-797-4621 cell: 505-688-2129


mailto:[email protected]


EXHIBIT D


From: <[email protected]> Date: Wed, Apr 8, 2020 at 2:43 PM Subject: Status: OPRA Request To: <[email protected]>, <[email protected]>, <[email protected]>

City of Trenton

Open Public Records Act (OPRA) Request

Reference # OPR-2020-01499

Date Received: 04/08/2020

Dear Isaac Avilucea,

This email serves as receipt of closure of your request by the City of Trenton.

The request sought access to the following:

Please accept this request under the Open Public Records Act (OPRA), N.J.S.A 47-1A-1 et seq., and the common law right of access for copies, either in paper or electronic form, of the following: All body camera footage from the April 3 encounter Trenton Police had with a man in crisis outside of St. Francis Medical Center. All use of force reports filled out by officers involved in the arrest CAD reports Incidents for same 911 call or another other call for the same Dash cam and police radio transmissions for the same Identity of the man who died for same

Below is a summary of how your request was handled.

Department Assigned Status Police Denial

If your request for access to a government record has been denied or unfilled within the seven (7) business days required by law, you have a right to challenge the decision by the City of Trenton to deny access. At your option, you may either institute a proceeding in the Superior Court of New Jersey or file a complaint with the Government Records Council (GRC) by completing the Denial of Access Complaint Form. You may contact the GRC by toll-free telephone at 866-850-0511, by mail at P.O. Box 819, Trenton, NJ, 08625, by e-mail at [email protected], or at their web site at www.state.nj.us/grc. The GRC can also answer other questions about the law. All questions regarding complaints filed in Superior Court should be directed to the Court Clerk in your County.

Sincerely,

City of Trenton







http://www.state.nj.us/grc

EXHIBIT E


From: Isaac Avilucea <[email protected]> Sent: Wednesday, April 8, 2020 2:59 PM To: Dwayne M. Harris <[email protected]> Subject: reason for denail Hi Mr. Harris: No reason was given for the denial of my OPRA request for body camera footage and other relevant materials as it relates to man who died in police custody outside of St. Francis. Can you please provide clarity on that? -- Isaac Avilucea Reporter The Trentonian Office: 267-797-4621 cell: 505-688-2129


EXHIBIT F


From: Dwayne M. Harris <[email protected]> Date: Wed, Apr 8, 2020 at 6:48 PM Subject: Re: reason for denail To: Isaac Avilucea <[email protected]> Isaac, I apologize. I have to get Ms. Lee back into the swing of things after an extended absence. That incident is still being investigated by the Police and they are not yet able to release that footage. Dwayne M. Harris, RMC, CMR, QPA, RPPO Municipal Clerk City of Trenton 609-989-3187 [email protected] WARNING: This electronic transmission and any attachments hereto may be considered a public document and is subject to the NJ Open Public Records Act. If there is anything that you would not want the general public to see, I would suggest you utilize an alternate means of communication. This communication is for the intended recipient and disclosure of its content is unauthorized. If you have received this transmission or a copy thereof in error, you are instructed to immediately and permanently delete this transmission and any attachments.





Documents

PASHMAN STEIN WALDER HAYDEN A Professional ......PASHMAN STEIN WALDER HAYDEN A Professional Corporation Court Plaza South 21 Main Street, Suite 200 Hackensack, NJ 07601 Ph: (201) 270-4930