Professional Documents
Culture Documents
DONALD HYDE, JACKIE HYDE V NJ Dept of Children and Families
DONALD HYDE, JACKIE HYDE V NJ Dept of Children and Families
Plaintiffs,
-vsNEW JERSEY DEPARTMENT OF
CHILD PROTECTION AND
PERMANENCY, MS. ESPOSITO,
ABC CORPS. I-V (fictitious
entities whose true
identities are presently
unknown)
and JOHN AND JANE
DOES I-V, (fictitious
persons whose true
identities are presently
unknown),
Defendants.
I.
1. 1
The
United
States
District
Court
has
original
1331 as a
U.S.C.
1391(a) (2),
the events,
activity,
and
THE PLAINTIFFS
II.
2.1
The
plaintiffs,
V.H.
and T.H.
are minor
children
of
3.1
The defendant,
and Permanency
THE DEFENDANTS
( "NJDCP&P")
is
employee
of
NJDCP&P,
and
therefore
is
public
employee who at all relevant times acted under color of state lall.
3.3 The defendants ABC Corps. I-V and John and Jane Does I-V
are fictitious entities and individuals whose identity,
actions
On
or
about
THE OCCURRENCE
November
28,
2012,
Ms.
Esposito,
as
an
Upon
information
and
belief,
the
investigation
11as
4.4. Ms.
even
though she kneH doing so \/as not permitted under the law pursuant
to N.J.S.A.
4.5
9:6-8.10a.
Ms.
Esposito
disclosed
the
fact
that
an ongoing
Jackie
Hyde
about
28,
what
she
2012,
Ms.
did
and
Esposito
that
she
disclosed to the investigation to the Vlrong V.H. and that she made
a mistake in doing so.
4. 8
The
investigation of
child abuse
concerning '1'. H.
was
closed.
4.9
no evidence whatsoever of
the
fact
that
child abuse
As
result
of
the
wrongful
disclosure
of
the
investigation by defendants,
Specifically,
psychological,
and
all
plaintiffs
psychiatric
damages
suffered
as
emotional,
result
of
the
Further,
Jackie Hyde,
injuries,
forced
2012,
plaintiffs discovered
that defendants, NJDCP&P, Ms. Esposito, ABC Corps. I-V and John and
Jane Does I-V purposefully, l'lillfully, v1antonly and/or negligently
disclosed protected private information concerning a child abuse
investigation to individuals outside the scope of the investigation
and who had no right to such information and further did not have
the appropriate protocols and procedures in place that 1'/0uld have
prevented the lvrongful disclosure of the investigation.
4.16
various
investigation,
laws
and the
requiring
the
facts
of
NJDCP&P
investigation.
4.18
Plaintiff
Jackie
Hyde
suffered severe
and permanent
Further,
as
direct
and
proximate
result
of
the
local dance
under
investigation
for
child
abuse
spread
through
her
N.J.S.A.
9:6-8.10a,
for
compensatory and
punitive
damages,
SECOND COUNT
4.23 Plaintiffs repeat and re-allege all prior allegations as
though set forth fully herein.
4.24
the
plaintiffs
resulting
in
and
a
the
due
deprivation
process
of
rights
their
of
rights,
the
plaintiffs
privileges
and
interest and
cost of suit.
THIRD COUNT
4.26
~'
vlithin the
4.29
As a
plaintiffs, Donald Hyde and Jackie Hyde have both suffered per quod
damages for the loss of their spouses'
aid,
comfort,
conjugal