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ty Company 103 Camegie Center Suite 300 2 Princeton, NJ 08540 gy & (609)306-2595 WB wt Counsel for Plaintifts % Sharon Papp; Steven Riccitello; Dani Pi SUPERIOR COURT OF NEW SERSEY® oa Chitren; Carol Raymond; Christopher P, z LAW DIVISION-MERCER COUNTY: 0 Donnelly; Michael Bender and Christopher : S ee M. Quaste 2, DOCKET NO. Plaintiffs, vs. David Dudeck, individually, andinhis CIVIL ACTION official capacity as Chief of the Princeton Police Department; the municipal entity: COMPLAINT. now known as Princeton, New Jersey; and (with Jury Demand) the Princeton Police Department Defendants. Plaintiffs, Sharon Papp, Steven Riccitello, Daniel Chitren, Carol Raymond, Christopher Donnelly, Michael Bender and Christopher M. Quaste (“Plaintiffs”), by way of Complaint against Defendants, David Dudeck, individually, and in his official capacity as Chief of Defendant, the Princeton Police Department (“Dudeck”); the now consolidated borough form of municipal entity known as “Princeton, New Jersey,” individually, and as suecessor-in-interest to the former municipal entities known as the “Borough of Princeton” and “Princeton Township” (“Princeton”); and the now consolidated “Princeton Police Department,” individually, and as Suecessor-in-interest to the former “Borough of Princeton Police Department” and “Princeton ‘Township Police Department” (“PPD”) (with Dudeck, Princeton and the PPD hereinafter collectively referred to as “Defendants”), respectively says: THE PARTIES 1. Atall times relevant hereto, Plaintiff, Sharon Papp was employed as a police officer by the PPD and was a member of a protected class (gay/female/disabled) under the New Jersey Law Against Dis ation (“LAD”), NW.S.A. 10:51, ef. seq. 2. Atall times relevant hereto, Plaintiff, Steve Riccitello was employed as a police officer by the PPD and was a member of a protected class (heterosexual male) under the LAD. 3, At all times relevant hereto, Plaintiff, Carol Raymond was employed as apolice officer by the PPD and was a member of a protected class (gay/female) under the LAD. 4. ACall times relevant hereto, Plaintiff, Daniel Chitren was employed as a police officer by the PPD and was a member of a protected class (disabled/heterosexual male) under the LAD. 5. Atall times relevant hereto, Plaintiff, Christopher P, Donnelly was employed asa police officer by the PPD and was a member of a protected class (heterosexual male) under the LAD. 6. tall times relevant hereto, Plaintiff, Michael Bender was employed as a police officer by the PPD and was a member of a protected class (heterosexual male) under the LAD. 7, Atall times relevant hereto, Plaintiff, Christopher M. Quaste was employed as a police officer by the PPD and was a member of a protected class (heterosexual male) under the LAD. 8. Atall times relevant hereto the PPD was the employer of Plaintiffs as that term is defined under the LAD. 9. Atall times relevant hereto, Dudeck was employed by Princeton as the Chief’ of Police for the PPD, and had supervisory authority over Plaintiffs under the LAD, both individually, and as an agent of the PPD and Princeton. 10. Atall times relevant hereto, Defendant, Princeton was responsible for hiring and supervising Dudeck, and both overseeing and controlling various administrative and personnel functions of the PPD and Dudeck, as its agent, and other employees and agents of the PPD and Princeton, including, but not limited to, paying Plaintiffs and providing benefits, and was, inter alia, required to provide Plaintifts with a work environment free from discrimination, harassment, intimidation, retaliation and hostility under the LAD. FIRST COUNT (gender/sexual orientation/sexual harassment/disability discrimination-LAD) 11, Plaintiffs repeat and restate all of the allegations set forth in paragraphs 1 through 10 above, as if repeated verbatim herein. 12, From 2008 until Dudeck’s forced leave from the PPD in 2013, Defendants have engaged in an egregious and continuing pattern of gender discrimination, sexual orientation discrimination, disability discrimination and sexual harassment against Plaintifis as women (Papp and Raymond), gay officers (Papp and Raymond), heterosexual males (Riecetello, Chitren, Donnelly, Bender and Quaste) and disabled officers (Chitren, Papp), which was patently abusive and created a hostile work environment at the PPD, with such acts of gender discrimination, sexual orientation discrimination, disability discrimination and sexual harassment by Dudeck and other personnel and agents of Princeton including, inter alia: (a) Dudeck calling gay female officers (Papp and Raymond) and other women (regardless of their sexual orientation) “dykes,” and repeatedly using the offensive phrase “put his/their finger in the dyke” when referring to their work for the PPD and in their presence; (>) Dudeck repeatedly asking Plaintiff, Chitren about the size of his penis and referring to the penis of an African-American PPD officer in the presence of Plaintifls, including