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  • 1.  Support related license suspensions / Civil Rights Action

    Posted 03-29-2016 05:11 PM
    UPDATE: Mediation was supposed to move forward on March 18 with an AOC representative present to discuss potential changes to the system.

    On March 16, the AG's office indicated that they saw no point in moving forward without the AOC as a defendant. As many who commented / contacted me may recall, I didn't include them after a whole, whole lot of research made it appear they weren't necessary and it would potentially complicate matters with immunity defenses (having to distinguish between judicial and non-judicial roles). During oral argument in July, Judge Jacobson seemed to agree with me, but left the door open on the issue, saying a motion might be requried to address it. I was expecting one from the defendants, but it never came.

    So, I've now filed a motion to amend the complaint and, if that application is granted, to have us return to mediation. A copy is on the site: http://dpdlaw.com/kavadas.htm


    <x-sigsep>

    David Perry Davis, Esq.
    ----------------------------------------------------
       www.FamilyLawNJ.pro
    ----------------------------------------------------
    112 West Franklin Avenue
    Pennington, NJ 08534
    Voice: 609-737-2222
    Fax:    609-737-3222

    </x-sigsep>


  • 2.  RE: Support related license suspensions / Civil Rights Action

    Posted 04-07-2016 06:52 PM
    UPDATE: Astounding... The State isn't fighting something.

    The opposition to the motion to amend the complaint (to include the AOC and individual probation officers in their administrative / non-judicial capacities) was due today. Just received it - the State is consenting to the motion. Unless I'm dreaming. I was expecting "it's too late in the game" / "we'd need different discovery" / immunity defenses, etc - something. OCR copy below, PDF of letter is: www.dpdlaw.com/    Kavadas_Defendants_No_Opp_To_AmendMotion.pdf

    So, the next step is a return to mediation, with the AOC now present and the chance to make progress.

    (One question remains, although not key - the letter complains the AOC wasn't served with the motion, but the AG's office was. Does not the AG's office represent the AOC? Not sure it's worth the time to research it out, but if anyone knows off the top of your head, I'm curious).



    David Perry Davis, Esq.
    ----------------------------------------------------
       www.FamilyLawNJ.pro
    ----------------------------------------------------
    112 West Franklin Avenue
    Pennington, NJ 08534
    Voice: 609-737-2222
    Fax:    609-737-3222



    April 7, 2016

    Via Fax (609)571-4463 and Regular Mail
    The Honorable Mary C. Jacobson
    New Criminal Courthouse
    500 South Warren Street
    Trenton, NJ 08650

    Re:<x-tab>     </x-tab>Kavadas v. Martinez
    <x-tab>        </x-tab>Docket No. MER-L-1004-15

    Dear Judge Jacobson:

    We represent Defendants Raymond P. Martinez, the New Jersey
    Motor Vehicle Commission, John Jay Hoffman., Esq., the State of
    New Jersey, Natasha Johnson, and the Department of Human
    Services, Division of Family Development, Office of Child
    Support Services in the above-captioned matter. Please consider
    this letter in short response to Plaintiffs' Motion for Leave to
    File an Amended Complaint.

    Defendants do not oppose Plaintiffs' Motion. However, if
    the Court is inclined to grant the relief Plaintiffs seek,
    Defendants respectfully request that the Court clarify in any
    resulting order that all Defendants' responsive pleadings and/or
    motions are due 35 days from the date of service of the Amended
    Complaint on each Defendant. Attached to this letter is the
    Division of Law's most recent policy regarding Acceptance of
    Service.

    Furthermore, Defendants wish to bring to the Court's
    attention that Plaintiffs did not serve the Administrative
    Office of the Courts and other defendants to be named in the
    Amended Complaint with a copy of the Motion for Leave to File an
    Amended Complaint.


    April 7, 2016
    Page 2

    Please do not hesitate to contact me if you have any
    questions.

    Respectfully submitted,

    ROBERT LOUGY
    ACT NG ATTORNEY GENERAL OF NEW JERSEY
    By:
    Shana Bellin (907512012)
    Deputy Attorney General
    Enclosure
    cc: David Perry Davis via electronic mail
    Susanna Morris via electronic mail


    Michelle M. Smith, Esq., Clerk
    Superior Court of New Jersey
    Richard J. Hughes Justice Complex
    25 W. Market Street, 6~" Floor North Wind
    P.O. Box 971
    Trenton, NJ 08625-0971
    Re: In the Matter of the Attorney General of New Jersey
    Docket No. L-703-53
    Dear Ms. smith:
    JoxN J.Hoxz~,rr
    ActrngAtGorney Geneml
    Jeffrey S. Jacobson
    Director
    Pursuant to IZ. 4:4-4(a)(7) and R. 2:5-1(e), in addition to myself, I hereby designate the following
    persons to accept service for the Attorney General of the State of New Jersey, revoking any and all
    former designations:
    Kevin Jesperson
    Jeffrey Jacobson
    1Vlichael Waltexs
    Michelle Miller
    Lisa Puglisi
    Eileen McManimon
    Jessica Hamilton
    Ellen Seitz
    Lisa Haws
    Evelyn Williams
    Janice Rutherford
    Linda Munter
    Sincerely,
    ~.
    ohn J. IIof ' an
    Acting Attoxney General
    Neur Jersey Is An Equal Opportunity Employer •Printed on Reeyelecl Paper and Recyclable



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