Rise Against Hate vs. Bridgewater Township

SOM-L-000397-22 04/08/2022 11:45:51 AM Pg 1 of 7 Trans ID: LCV20221413411
LAW OFFICES OF ERIC A. SHORE

Megan Jeffery, Esq.
20 Brace Road, Suite 325
Cherry Hill, NJ 08034
Direct: 856-433-6225
MeganJ@EricShore.com
Attorney for Plaintiff, Rise Against Hate.Org
RISE AGAINST HATE.ORG, A Nonprofit NEW JERSEY SUPERIOR COURT

Organization and a 501(c)(3) Public Charity; SOMERSET COUNTY
LAW DIVISION
Plaintiff,
Civil Action
v.
DOCKET NO. ________________________
BRIDGEWATER TOWNSHIP, and LINDA
DOYLE in official capacity as records VERIFIED COMPLAINT
custodian.
Defendants.
Plaintiff, Rise Against Hate.Org (hereafter “Plaintiff”), a New Jersey Nonprofit
Corporation through its undersigned counsel, Law Offices of Eric A. Shore, hereby pleads:
CAUSE OF ACTION & VENUE
1. This is an action alleging violation of the New Jersey Open Public Records Act
(OPRA), N.J.S.A. 47:1A-1 to -18 and a violation of Plaintiff’s common law right to access to
public government records. Plaintiffs bring this action because the herein named Defendants have
unlawfully and improperly denied Plaintiff access to government records that are not exempt.
2. The Court has subject matter jurisdiction pursuant to N.J.S.A. 47:1A-6 and the
common law right of access.
3. Venue is properly laid in Somerset County pursuant to R. 4:3-2(a)(2). because
Defendant, Somerset County is a public entity located in Somerset County.

IDENTIFICATION OF PARTIES
4. Plaintiff is a non-profit organization, formed under the laws of the State of New
Jersey, which maintains an office at 12 Manor House Court, Cherry Hill, New Jersey 08003.
5. Plaintiff was and is currently recognized by the United States Internal Revenue
Service as a 501(c)(3) Public Charity.
6. Defendant, Bridgewater Township (hereafter “Township”), is a municipal public
entity formed and located within Somerset County, New Jersey.
7. Defendant, Linda Doyle, at all times pertinent hereto, was and is the Township’s
Clerk and Records Custodian.
FACTUAL ALLEGATIONS
8. Plaintiff’s purpose is to raise awareness about racism, civil rights, investigate racial
disparities, and provide public awareness in law.
9. Plaintiff has a key focus in New Jersey, and accomplishes its mission through many
facets, most important of which is by disseminating information, such as its investigation results
to citizens in towns such as Township, civil rights and discrimination training and support events
to citizens in towns and by keeping citizens in towns informed on current events that affect or
concern the civil rights of citizens who are members of historically marginalized communities.
10. Plaintiff also acts as a watch dog organization that monitors municipalities, such as
Township, to ensure that they, and their agents, employees, law enforcement and officials, are
honoring the civil rights of their residents.
11. Upon information and belief, Township has information concerning police officers’
names, salaries, ages, years of service, age and gender.

12. Upon information and belief, Township maintains and/or has access to these
records.
13. On or about February 24, 2022, with its mission in mind, Plaintiff submitted an
OPRA request to Township via electronic mail, a true and complete copy is e-filed as Exhibit A.
Plaintiff’s OPRA request asked for “Please provide police officers names employed by
Bridgewater police, salary, years of service, age, and gender at present date in a tab delimitated
format.”
14. Township provided salary information, without any other information. Exhibit B
COUNT I
Violation of OPRA, N.J.S.A. 47:1A-1 to -18.
15. Plaintiff repeats and incorporates by way of reference each and every allegation
contained in the previous paragraphs as if fully set forth herein.
16. The records requested by Plaintiff are “government records” pursuant to N.J.S.A.
47:1A-1.1.
17. Pursuant to N.J.S.A. 47:1A-1, all “government records” must be “readily
accessible” to the citizens of this State unless specifically exempt by law.
18. To date, Defendants’ have not made the requested documents available to Plaintiff
despite Plaintiff’s OPRA request, despite the request being for a specific record and being in a
narrow identifiable window of time.
19. As a result of Defendants’ wrongful and illicit denial of Plaintiff’s OPRA request,
Plaintiff has suffered and continues to suffer damages.

WHEREFORE, Plaintiff demands judgment against Defendants that, Defendants
immediately produce complete and responsive records to Plaintiff’s OPRA Request(s); a
declaration by the Court that Defendants wrongfully denied Plaintiff’s OPRA Request; pursuant
to N.J.S.A. 47:1A-6, an award against Defendants for Plaintiff’s reasonable attorneys’ fees; an
award against Defendants to reimburse Plaintiff’s court costs, and pre and post judgement interest;
and any other relief that the Court deems just and equitable.
COUNT II
Violation of Plaintiff’s Common Law Right To Access Public Documents
20. Plaintiff repeats and incorporates by way of reference each and every allegation
contained in the previous paragraphs as if fully set forth herein.
21. The employment records are a public record, that are populated and filled out at
least in part by Township and its officials, officers, employees, and agents.
22. The records are a public record filed or accessible within Township’s office.
23. Plaintiff, as a New Jersey formed nonprofit and civil rights watch dog organization,
has a clear and undeniable interest in Township’s public records to accomplish Plaintiff’s mission
to combat gender disparities in law enforcement hiring and salaries, and help protect citizens’ civil
rights through the dissemination of information.
24. Township may have a minimal privacy interest in the non-disclosure of its these
records.
25. Even if Township had an interest in non-disclosure law enforcement hiring records,
it is significantly outweighed by Plaintiff’s mission and the public’s interest in Plaintiff’s mission
and works.
26. Despite Plaintiff’s request for Township’s documents to date, Defendants have not
produced all of the requested documents.
WHEREFORE, Plaintiff demands judgment against Defendants that, Defendants
immediately produce complete and responsive records to Plaintiff’s OPRA Request(s); a
declaration by the Court that Defendants wrongfully denied Plaintiff’s OPRA Request; pursuant
to N.J.S.A. 47:1A-6, an award against Defendants for Plaintiff’s reasonable attorneys’ fees; an
award against Defendants to reimburse Plaintiff’s court costs, and pre and post judgement interest;
and any other relief that the Court deems just and equitable.
REQUEST FOR INSURANCE INFORMATION PURSUANT TO R.4:10-2(b)
Defendants are hereby requested to provide copies of any and all policies of insurance
which may provide coverage for the claims and causes of action contained in this complaint.
TRIAL COUNSEL DESIGNATION
Plaintiff hereby designates Megan Jeffery of the Law Offices of Eric A. Shore as trial
counsel.
By: Megan Jeffery

MEGAN JEFFERY, ESQUIRE
Attorney for Plaintiff, Rise Against Hate. Org
Dated: April 5, 2022
R. 4:5-1 CERTIFICATION
I, Megan Jeffery, Esq., hereby certify the following:
1. I am an attorney, licensed to practice law in the State of New Jersey and am
responsible for the above captioned matter.

2. To the best of my knowledge and belief, this matter in controversy is not the subject
of any other action pending in any Court or of a pending arbitration proceeding, nor is any such
proceeding contemplated at this time.
3. I certify that confidential personal identifiers have been redacted from documents
now submitted to the court, and will be redacted from all documents submitted in the future in
accordance with Rule 1:38-7(b).
By: Megan Jeffery

MEGAN JEFFERY, ESQUIRE
Attorney for Plaintiff, Rise Against Hate. Org
Dated: April 5, 2022
VERIFICATION
I, Benjamin A. Shore, of full age, deposes and says:
1. I am the current Executive Director of Rise Against Hate. Org, the Plaintiff in this
matter.
2. I have read the Verified Complaint. The factual allegations in 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, if any, 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.

Electronically Signed 2022-04-07 19:51:13 UTC - 69.255.66.142
/S/ _______________________
Nintex AssureSign® 8e40b4e7-6dcd-4b5c-9d65-ae700146d7a5
Dated: April 7, 2022 BENJAMIN A. SHORE

Rise Against Hate vs. Bridgewater Township

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SOM-L-000397-22 04/08/2022 11:45:51 AM Pg 1 of 7 Trans ID: LCV20221413411

LAW OFFICES OF ERIC A. SHORE

RISE AGAINST HATE.ORG, A Nonprofit NEW JERSEY SUPERIOR COURT

Plaintiff, Rise Against Hate.Org (hereafter “Plaintiff”), a New Jersey Nonprofit

CAUSE OF ACTION & VENUE

common law right of access.

3. Venue is properly laid in Somerset County pursuant to R. 4:3-2(a)(2). because

Defendant, Somerset County is a public entity located in Somerset County.

Service as a 501(c)(3) Public Charity.

6. Defendant, Bridgewater Township (hereafter “Township”), is a municipal public

entity formed and located within Somerset County, New Jersey.

Clerk and Records Custodian.

disparities, and provide public awareness in law.

honoring the civil rights of their residents.

names, salaries, ages, years of service, age and gender.

contained in the previous paragraphs as if fully set forth herein.

17. Pursuant to N.J.S.A. 47:1A-1, all “government records” must be “readily

accessible” to the citizens of this State unless specifically exempt by law.

narrow identifiable window of time.

Plaintiff has suffered and continues to suffer damages.

WHEREFORE, Plaintiff demands judgment against Defendants that, Defendants

immediately produce complete and responsive records to Plaintiff’s OPRA Request(s); a

Violation of Plaintiff’s Common Law Right To Access Public Documents

contained in the previous paragraphs as if fully set forth herein.

rights through the dissemination of information.

produced all of the requested documents.

WHEREFORE, Plaintiff demands judgment against Defendants that, Defendants

immediately produce complete and responsive records to Plaintiff’s OPRA Request(s); a

REQUEST FOR INSURANCE INFORMATION PURSUANT TO R.4:10-2(b)

TRIAL COUNSEL DESIGNATION

By: Megan Jeffery

I, Megan Jeffery, Esq., hereby certify the following:

1. I am an attorney, licensed to practice law in the State of New Jersey and am

responsible for the above captioned matter.

proceeding contemplated at this time.

accordance with Rule 1:38-7(b).

By: Megan Jeffery

Dated: April 5, 2022

I, Benjamin A. Shore, of full age, deposes and says:

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

agents unless so stated.

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

Electronically Signed 2022-04-07 19:51:13 UTC - 69.255.66.142

Dated: April 7, 2022 BENJAMIN A. SHORE

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