Lazaro Complaint

OCN-L-001530-23 06/30/2023 1:25:50 PM Pg 1 of 19 Trans ID: LCV20231983873
LAW OFFICES JOHN R. TATULLI

John R. Tatulli, Esq. (Id. No.: 041462004)
125 Half Mile Road, Suite 200
Red Bank, New Jersey 07701
Ph. 732.842.4646
www.tatullilaw.com
Attorneys for Plaintiff
RENE LAZARO, SUPERIOR COURT OF NEW JERSEY

LAW DIVISION - OCEAN COUNTY
Plaintiff,
DOCKET NO.
vs.
BRICK TOWNSHIP PUBLIC SCHOOLS, CIVIL ACTION

BRICK TOWNSHIP BOARD OF
EDUCATION, THOMAS G. FARRELL,
Superintendent, and DANA COMPLAINT AND JURY DEMAND
TRIANTAFILLOS,
Defendants.
Plaintiff, Rene Lazaro, a resident of the State of New Jersey, by way of Complaint
against the Defendants, says:
THE PARTIES
1. Plaintiff Rene Lazaro ( “Plaintiff/Lazaro”), is a resident of Monmouth County, New
Jersey. She was employed in Ocean County by the Brick Township School District and the Brick
Township Board of Education as a teacher at the Lanes Mill Elementary School and the Veterans
Memorial Middle School.
2. Defendant Brick Township (“District”) is a public school district in Ocean County, New
Jersey and Plaintiff’s former employer with offices located at 101 Hendrickson Avenue, Brick,
New Jersey.
3. Defendant Brick Township Board of Education (“Board”) is a body of elected officials
who are responsible for overseeing the operations of the Brick Townships Public Schools with
offices located at 101 Hendrickson Avenue, Brick, New Jersey.
4. Defendant Thomas G. Farrell (“Farrell”) is the superintendent and terminated Plaintiff
from her employment.
5. Defendant Dana Triantafillos (“Triantafillos”) is a school principal at the Veterans
Middle School and a supervisor of Plaintiff.
NATURE OF THE ACTION
6. Plaintiff, Rene Lazaro, brings this action against her former employer, Defendants School
District, the Board, Farrell and Triantafillos.
7. Plaintiff is a school teacher in New Jersey public schools who was initially hired to work
as a special education teacher at the Lanes Mill Elementary School in the District.
8. Key personnel involved in Plaintiff’s case were as follows:

• Superintendent - Dr. Thomas Farrell
• Director of Human Resources - William Kleissler
• Director of Special Services - Kristen Hanson ( Resigned, last day June 22 )
• Secondary Special Education - Ann Marie Dayton
• Lanes Mill Principal - Dr. Daniel O’Cone
• Veterans Memorial Principal - Dana Trianafillos
• Nicole Pannucci - Science Department Middle School
9. On November 15, 2021 - First day of Lanes Mill Elementary, Plaintiff shadowed the
temporary teacher in the room and then she was left on my own from then on. The teacher that
was in the room was injured. The class had many substitutes for no one wanted to be in room.
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10. January 2022. Lanes Mill School Principal O’Cone told Plaintiff that the District hired
another autism teacher and he was not sure of what was going to be happening with Plaintiff.
Either she was getting transferred or they were extending the program. O’Cone said that he knew
nothing about the new hire which upset him because after all he is the principal.
11. Apparently the other teacher was hired before Christmas. O’Cone did not tell Plaintiff
because he didn't want to ruin her holiday so he knew before Christmas break. Principal said
that Plaintiff did wonderful work and she was not to take this personally. He said, “there is a
student over at the middle school who needs you and your help.” We assumed the reason for the
transfer was a certificate issue. He said the new person was going to be starting in 6 weeks.
Plaintiff let him know about her significant disappointment.
12. On or about January 24, 2022, the Board of Education held their monthly meeting. It was
in the minutes that Plaintiff found out she was to be transferred over to the Veteran’s Middle
School. No one told Plaintiff of this transfer. She only notified in the Board minutes.
13. The next day Plaintiff went to O’Cone and said, "I read it in the minutes that I'm to be
transferred over to the Middle School". He had his head down and was looking at papers. He
told Plaintiff, “it’s okay, you'll be fine.”
14. In or around February 2022, Plaintiff met with Nicole Pannucci and discussed with her
that Plaintiff was unfamiliar with teaching science and uncomfortable with the transfer to
Veteran Middle School. Pannucci said teaching all three subjects in a middle school was no
different than teaching all three subjects at an elementary school level. Plaintiff believed this to
be inaccurate because a teacher needs to take Praxis in order to teach science in middle school.
15. In or around March 7 , 2022 – Plaintiff began her first day at Veteran’s Middle School.
3
Plaintiff subsequently contacted the Ocean County Dept. of Superintendent, and spoke to a
woman named Debbie. Plaintiff advised her she was thinking about taking an teaching position,
however she was not certified in 2 of the 3 subjects. She said that she can only be ICS in Science
and Math. Plaintiff was not permitted to be the lead teacher that she was assigned to be at the
Veteran’s Middle School (“Veterans”) which she became pursuant to the transfer.
16. Plaintiff then advised her supervisors that according to N.J.S.A. 6A:9B-5.1 she was not
permitted to teach students that she was being required to do according to her transfer from
Lanes Mills to Veterans. (b) In addition to the requirements set forth under section 9B-5.1, the
certificate holder shall obtain any license, certificate, or authorization required by State or
Federal law, a licensing board, or N.J.A.C. 6A:9B-4.1 and 4.2 for the individual to serve in a
position. Additionally, the district board of education that is considering employing the
individual shall ensure the candidate holds all necessary licenses, certificates, or authorizations.
17. Plaintiff was then advised by Veterans School Principal Dana Triantafillos that she was
being fired effective June 30.
18. Plaintiff subsequently sent an e-mail to Defendant Thomas G. Farrell an email requesting
a “statement of reasons” or a further explanation of why she was being terminated. Farrell never
responded to Plaintiff’s request for a statement of reasons as required by N.J.S.A. 18A:27-3.2.
19. Prior to her termination on June 30, Plaintiff was presented with a new contract to be a
teacher in the District for the 2022-2023 school year by Human Resources.
4
20. Within days of being presented with the new contract for 2022-23 school year, the
Human Resources Department voided the contract and advised Plaintiff that she was no longer
being offered a position in the District. She would be terminated effective on June 30.
21. Plaintiff also discovered that even though she was told the District was having
“budgetary cutbacks,” the District in fact hired a teacher more than 15 years younger than
Plaintiff to replace her in the District.
22. After her termination on June 30 from the District, Plaintiff was advised by the pension
board that all of the contributions to her pension had not been made while she was working in the
Brick School District.
23. In fact, the District violated Plaintiff’s rights to her pension payments by making false
payments to another account not related to Plaintiff’s pension account.
COUNT ONE
(VIOLATION OF C.E.PA.)
24. The above paragraphs are repeated at length as if set forth herein.
25. At all times relevant, Plaintiff was employed by Defendant District and Board of
Education.
26. The District violated Plaintiff’s rights under the state’s “whistleblower law” after she
objected to and reported violations of the state education laws and regulations. In October of
2021, Plaintiff was hired as a special ed teacher by the Brick Township Board of Education after
interviewing for a position at Lanes Mill Elementary School. She started teaching there on
November 15 and for the first 2 months, was performing satisfactorily.
5
27. In January 2022, for unexplained reasons, Plaintiff received notification that she was
being transferred to Veterans Memorial Middle School to teach multiple subjects in a self-
contained special education classroom. Even though she did not have the proper credentials to
teach in this environment, the District purposely and knowingly placed her in that classroom
where she was forced to teach outside her certification area.
28. Plaintiff alerted the district that her transfer violated the New Jersey education
regulations, specifically, N.J.A.C. 6A:9B-5.1 and 6A:9B-5.4, which require proper certifications
for education instruction in the subjects to which the district assigned her. She confirmed the
violation of these state regulations with the Ocean County Department of Education. She
reported her objections and the violations to several members of the District. In its retaliatory
response, the District terminated her effective June 30.
29. The actions taken the District and the Defendants named herein are clear violations of the
Conscientious Employee Protection Act (C.E.P.A.) N.J.S.A. 34:19-1 et seq.
30. CEPA provides, in pertinent part: an employer shall not take any retaliatory action
against an employee because the employee does any of the following: a. Discloses, or threatens
to disclose to a supervisor or to a public body an activity, policy or practice of the employer, or
another employer, with whom there is a business relationship, that the employee reasonably
believes: (1) is in violation of a law, or a rule or regulation promulgated pursuant to law,
including any violation involving deception of, or misrepresentation to, any shareholder,
investor, client, patient, customer, employee, former employee, retiree or pensioner of the
employer or any governmental entity, or, in the case of an employee who is a licensed or
certified health care professional, reasonably believes constitutes improper quality of patient
care; or (2) is fraudulent or criminal, including any activity, policy or practice of deception or
6
misrepresentation which the employee reasonably believes may defraud any shareholder,
employer or any governmental entity[.] N.J.S.A. 34:19-3(a).
31. Additionally, under CEPA, the employee objects to, or refuses to participate in any
activity, policy or practice which the employee reasonably believes: (1) is in violation of a law,
or a rule or regulation promulgated pursuant to law, including any violation involving deception
of, or misrepresentation to, any shareholder, investor, client, patient, customer, employee, former
employee, retiree or pensioner of the employer or any governmental entity, or, if the employee is
a licensed or certified health care professional, constitutes improper quality of patient care; (2) is
fraudulent or criminal, including any activity, policy or practice of deception or
misrepresentation which the employee reasonably believes may defraud any shareholder,
employer or any governmental entity; or (3) is incompatible with a clear mandate of public
policy concerning the public health, safety or welfare or protection of the environment.
32. In this case, Plaintiff both disclosed and objected to practices taking place at the school
district that she reasonably believed were in violation of laws, rules and regulations.
33. In retaliation, the District terminated Plaintiff’s contract as a direct and proximate result
of her protected activity under CEPA.
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34. As a direct, foreseeable, and proximate result of Defendants’ retaliatory actions, Plaintiff
has suffered lost earnings, injuries to present and future career opportunities, humiliation,
embarrassment, severe emotional distress, and pain and suffering.
WHEREFORE, Plaintiff demands judgment against Defendants for all damages sustained as
a result of Defendants’ wrongdoing, in an amount to be proven at trial, including:
a. Compensatory damages:
b. Consequential damages;
c. Incidental damages;
d. Treble damages;
e. Punitive damages;
f. Attorney’s fees and all recoverable costs; and
g. All other relief that the court deems equitable and just.
COUNT TWO
(AGE DISCRIMINATION)
36. Plaintiff is a female over 40 years old and a member of a protected class under the
under the New Jersey Law Against Discrimination.
37. Plaintiff was told she was being terminated as of June 30 due to “budget issues” in the
District. However, Plaintiff discovered through Board of Education meeting minutes that she was
being replaced by a significant younger teacher.
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38. Plaintiff was replaced by an employee more than 10 years younger than her for her
position.
39. The New Jersey Law Against Discrimination, specifically, N.J.S.A. 10:5-12, prohibits
discrimination of an employee on the basis of age.
40. At all times relevant, Defendant, regularly employed five or more persons bringing
Defendants within the provisions of the New Jersey Law Against Discrimination prohibiting
employers or their agents from discriminating against employees based on their age.
41. Defendants’ conduct as alleged in this complaint constitutes an unlawful employment
practice in violation of the New Jersey Law Against Discrimination – N.J.S.A. 10:5-12.
42. As a direct, foreseeable, and proximate result of Defendants’ discriminatory actions,
Plaintiff has suffered lost earnings, injuries to present and future career opportunities,
humiliation, embarrassment, severe emotional distress, and pain and suffering.
d. Treble damages;
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COUNT THREE
(WRONGFUL DISCHARGE IN VIOLATION OF PUBLIC POLICY)
44. The retaliatory termination of Plaintiff constitutes a violation of numerous clear mandates
of public policy and is unlawful pursuant to the New Jersey Supreme Court’s decision in Pierce
v. Ortho Pharmaceutical Corp., 84 N.J. 58 (1980).
45. Plaintiff advised the District and its employees about proper teacher certification
requirements under New Jersey State Law pursuant to N.J.S.A. 6A:9B-5.1 and 9B-5.4.
46. The District and its employes and agents unlawfully retaliated against Plaintiff by
retaliating and terminating her in light of her reporting to the District about following the proper
laws and regulations required for all school districts in New Jersey.
47. The District unlawfully terminated Plaintiff for seeking to protect her rights under New
Jersey Law and the defendant’s own policies and procedures.
48. Defendants’ conduct as alleged in this complaint constitutes wrongful discharge in
violation of numerous clear mandates of public policy as set forth in Pierce v. Ortho.
49. As a direct, foreseeable, and proximate result of Defendants’ retaliatory actions, Plaintiff
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d. Treble damages;
COUNT FOUR
(NEGLIGENCE)
51. Defendants acted negligently and in violation of Plaintiff’s right when they failed to
provide a statement of reasons as required by N.J.S.A. 18A:27-3.2.
52. Plaintiff made a timely request for a “statement of reasons” pursuant to the statutory
regulations in order to protect her rights.
53. Defendants failed to provide any response whatsoever to Plaintiff’s request as required
under N.J.S.A. 18A:27-3.2.
54. Defendants owed a duty to Plaintiff to provide her with a statement of reasons under state
law.
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55. Defendants breached their duty of care when they intentionally failed to protect
Plaintiff’s rights by providing her with a statement of reasons as required under New Jersey State
Law.
56. Defendants further breached their duty to make proper contributions to Plaintiff’s pension
fund. Defendants improperly contributed to the wrong pension fund and denied Plaintiff her
lawful pension contributions.
57. Plaintiff has been denied her contributions to her pension fund in light of the District’s
failure to properly make the correct contributions to her pension.
58. Defendants owed a duty to Plaintiff to make correct and proper contributions to her
pension account.
59. Defendants failed to make the proper contributions to Plaintiff’s pension account and
breach their duty to Plaintiff. Plaintiff has been denied her lawful contributions to her pension
account.
60. As a direct, foreseeable, and proximate result of Defendants’ negligent actions, Plaintiff
d. Treble damages;
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COUNT FIVE
(BREACH OF CONTRACT)
62. A contract arises from proper acceptance, and must be sufficiently definite that the
performance to be rendered by each party can be ascertained with reasonable certainty. Weichart
Co. Realtors v. Tyan, 128 N.J. 427, 435 (1992).
63. Even after Plaintiff was advised her termination would be effective June 30, the District
and its employees and agents, presented Plaintiff with a contract for the 2022-23 school year.
64. Plaintiff accepted the terms of the 2022-23 contract and the District and representatives
of Human Resources for the District then cancelled the new contract.
65. As such, the District breached the terms and conditions of its contractual obligations with
Plaintiff after she accepted the new contract and it was subsequently terminated.
66. As a direct, foreseeable, and proximate result of Defendants’ breach, Plaintiff has
suffered lost earnings, injuries to present and future career opportunities, humiliation,
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d. Treble damages;
COUNT SIX
(BREACH OF IMPLIED GOOD FAITH AND FAIR DEALING)
68. “A covenant of good faith and fair dealing is implied in every contract in New Jersey.”
Wilson v. Amerada Hess Corp., 168 N.J. 236, 244 (2001).
69. Courts have recognized a breach of the implied covenant of good faith as an independent
cause of action (1) to allow the inclusion of additional terms and conditions not expressly set
forth in the contract, but consistent with the parties’ contractual expectations; (2) allow redress
for a contracting party’s bad faith performance of an agreement, when it is a pretext for the
exercise of a contractual right to terminate, even where the defendant has not breached any
express term; (3) and to rectify a party’s unfair exercise of discretion regarding its contract
performance. See, Seidenberg v. Summit Bank, 348 N.J. Super. 243, 257 (App. Div. 2002).
70. It is a violation of the implied covenant where the Defendant acts in bad faith or in
outright dishonesty. See, Pickett v. Lloyd’s, 131 N.J. 457 (1993).
14
71. It is a breach of the implied covenant where a party exercising its right to use discretion
“exercises its discretionary authority arbitrarily, unreasonably, or capriciously, with the objective
of preventing the other party from receiving its reasonably expected fruits under the contract.”
Wilson, supra, 168 N.J. at 251.
72. In breaching the contract as established by the District’s policies and procedures and the
subsequent contract as applied to Plaintiff, Defendants breached the implied covenant of good
faith and fair dealing.
73. The above-described actions further establish that Defendants failed to act in good faith
in carrying out the contract it had with Plaintiff.
74. As a direct, foreseeable, and proximate result of Defendants’ breach, Plaintiff has
d. Treble damages;
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COUNT SEVEN
(NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS)
76. As a result of their failure to make proper contributions to Plaintiff’s pension and its
failure to honor the subsequent contract presented to Plaintiff, Defendants have committed
negligent infliction of emotional distress against Plaintiff in that Defendants engaged in (i)
negligent or reckless conduct; (ii) the conduct was extreme and outrageous; (iii) the conduct
proximately caused the Plaintiff's emotional distress; and (iv) the emotional distress was
significant and severe.
77. Through the District’s failure to use reasonable case by failing to make the correct and
proper pension contributions to Plaintiff’s account, and failing to protect Plaintiff’s rights to
provide a statement of reasons for her termination as required by New Jersey Law, Defendants
have committed negligent infliction of emotional distress against Plaintiff in that Defendants
engaged in (i) negligent conduct; (ii) the conduct was significant and severe; (iii) Defendants
acted with negligence; (iv) the conduct proximately caused the Plaintiff's emotional distress; and
(iv) the emotional distress was severe.
78. By virtue of the foregoing, Defendants have committed negligent infliction of emotional
distress against the Plaintiff.
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79. As a direct, foreseeable, and proximate result of Defendants’ actions, Plaintiff has
d. Treble damages;
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DESIGNATION OF TRIAL COUNSEL
Pursuant to R. 4:25-4, John R. Tatulli, Esq., is designated as trial counsel in the within
action.
CERTIFICATION OF NO OTHER ACTIONS PURSUANT TO RULE 4:5-2
Pursuant to New Jersey Court Rule 4:5-1, counsel for Plaintiff hereby certifies that to his
knowledge, no matter related to this one is currently pending in either arbitration or litigation.
NOTICE OF LITIGATION HOLD
The parties are hereby require to preserve all physical and electronic information that
may be relevant to the issues to be raised, including but not limited to, Plaintiff’s employment, to
Plaintiff’s cause of action, and/or prayers for relief, to any defenses to same, and pertaining to
any party, including but not limited to, electronic data storage, closed circuit TV footages, digital
images, computer images, cache memory, searchable data, emails, spreadsheets, employment
files, memos, text messages and any and all online social networking sited including, but not
limited to Facebook, Twitter, LinkedIn, etc.,) and any other information and/or data and/or things
and/or documents which may be relevant to any claim or defense in this litigation.
Failure to do so may result in separate claims for spoliation of evidence and/or for
appropriate adverse inferences.
The obligation to preserve evidence begins when a party knows or should have known
that the evidence is relevant to future or current litigation. You are on notice of litigation and
therefore have an obligation to suspend your routine document retention/destruction policy and
18
put in place a ‘litigation hold’ to insure preservation of relevant documents.” Failure to do so has
been found to be ‘grossly negligent’ and may subject you to punishment.
JURY DEMAND
The Plaintiff demands a trial by jury on all of the triable issues of this complaint,
pursuant to New Jersey Court Rules 1:8-2(b) and 4:35-1(a).
s/John Tatulli
JOHN R. TATULLI, ESQ.
Attorney for Plaintiff
Date: June 29, 2023
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OCN-L-001530-23 06/30/2023
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1:25:50PM
PM Pg 1 of 1 Trans
TransID:
ID:LCV20231983873
LCV20231983873
Civil Case Information Statement

Case Details: OCEAN | Civil Part Docket# L-001530-23
Case Caption: LAZARO RENE VS BRICK TOWNSHIP Case Type: WHISTLEBLOWER / CONSCIENTIOUS EMPLOYEE
PUBLI C SCHOOLS PROTECTION ACT (CEPA)
Case Initiation Date: 06/30/2023 Document Type: Complaint with Jury Demand
Attorney Name: JOHN ROBERT TATULLI Jury Demand: YES - 6 JURORS
Firm Name: JOHN R. TATULLI, ATTORNEY AT LAW Is this a professional malpractice case? NO
Address: 125 HALF MILE RD STE 200 Related cases pending: NO
RED BANK NJ 07701 If yes, list docket numbers:
Phone: 7328424646 Do you anticipate adding any parties (arising out of same
Name of Party: PLAINTIFF : Lazaro, Rene transaction or occurrence)? YES
Name of Defendant’s Primary Insurance Company Does this case involve claims related to COVID-19? NO
(if known): Unknown
Are sexual abuse claims alleged by: Rene Lazaro? NO
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE

CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
Do parties have a current, past, or recurrent relationship? YES

If yes, is that relationship: Employer/Employee
Does the statute governing this case provide for payment of fees by the losing party? YES
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
Do you or your client need any disability accommodations? NO

If yes, please identify the requested accommodation:
Will an interpreter be needed? NO

If yes, for what language:
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
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)
06/30/2023 /s/ JOHN ROBERT TATULLI

Dated Signed

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OCN-L-001530-23 06/30/2023 1:25:50 PM Pg 1 of 19 Trans ID: LCV20231983873

LAW OFFICES JOHN R. TATULLI

RENE LAZARO, SUPERIOR COURT OF NEW JERSEY

BRICK TOWNSHIP PUBLIC SCHOOLS, CIVIL ACTION

against the Defendants, says:

1. Plaintiff Rene Lazaro ( “Plaintiff/Lazaro”), is a resident of Monmouth County, New

Memorial Middle School.

3. Defendant Brick Township Board of Education (“Board”) is a body of elected officials

offices located at 101 Hendrickson Avenue, Brick, New Jersey.

4. Defendant Thomas G. Farrell (“Farrell”) is the superintendent and terminated Plaintiff

from her employment.

5. Defendant Dana Triantafillos (“Triantafillos”) is a school principal at the Veterans

Middle School and a supervisor of Plaintiff.

NATURE OF THE ACTION

District, the Board, Farrell and Triantafillos.

8. Key personnel involved in Plaintiff’s case were as follows:

Plaintiff let him know about her significant disappointment.

told Plaintiff, “it’s okay, you'll be fine.”

being fired effective June 30.

responded to Plaintiff’s request for a statement of reasons as required by N.J.S.A. 18A:27-3.2.

Plaintiff to replace her in the District.

Brick School District.

payments to another account not related to Plaintiff’s pension account.

November 15 and for the first 2 months, was performing satisfactorily.

where she was forced to teach outside her certification area.

response, the District terminated her effective June 30.

Conscientious Employee Protection Act (C.E.P.A.) N.J.S.A. 34:19-1 et seq.

to disclose to a supervisor or to a public body an activity, policy or practice of the employer, or

believes: (1) is in violation of a law, or a rule or regulation promulgated pursuant to law,

employer or any governmental entity[.] N.J.S.A. 34:19-3(a).

fraudulent or criminal, including any activity, policy or practice of deception or

of her protected activity under CEPA.

embarrassment, severe emotional distress, and pain and suffering.

a result of Defendants’ wrongdoing, in an amount to be proven at trial, including:

f. Attorney’s fees and all recoverable costs; and

under the New Jersey Law Against Discrimination.

being replaced by a significant younger teacher.

discrimination of an employee on the basis of age.

41. Defendants’ conduct as alleged in this complaint constitutes an unlawful employment

42. As a direct, foreseeable, and proximate result of Defendants’ discriminatory actions,

humiliation, embarrassment, severe emotional distress, and pain and suffering.

a result of Defendants’ wrongdoing, in an amount to be proven at trial, including:

f. Attorney’s fees and all recoverable costs; and

(WRONGFUL DISCHARGE IN VIOLATION OF PUBLIC POLICY)

v. Ortho Pharmaceutical Corp., 84 N.J. 58 (1980).

Jersey Law and the defendant’s own policies and procedures.

48. Defendants’ conduct as alleged in this complaint constitutes wrongful discharge in

embarrassment, severe emotional distress, and pain and suffering.

a result of Defendants’ wrongdoing, in an amount to be proven at trial, including:

f. Attorney’s fees and all recoverable costs; and

provide a statement of reasons as required by N.J.S.A. 18A:27-3.2.

regulations in order to protect her rights.

under N.J.S.A. 18A:27-3.2.

lawful pension contributions.

failure to properly make the correct contributions to her pension.

embarrassment, severe emotional distress, and pain and suffering.

a result of Defendants’ wrongdoing, in an amount to be proven at trial, including:

f. Attorney’s fees and all recoverable costs; and

Co. Realtors v. Tyan, 128 N.J. 427, 435 (1992).

embarrassment, severe emotional distress, and pain and suffering.

a result of Defendants’ wrongdoing, in an amount to be proven at trial, including:

f. Attorney’s fees and all recoverable costs; and

(BREACH OF IMPLIED GOOD FAITH AND FAIR DEALING)