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Matthew A. Peluso, Esq. (#035721991) 103 Camegic Center Suite 300 Princeton, NJ 08540 (609)306-2595, Counsel for Plaintifts ‘Victoria Alberto: John Baker; Pete Bongiovanni; = SUPERIOR COURT OF NEW JERSEY Alan Brundage; Robert Camey; Frank Carrafiello; : LAW DIVISION-PASSAIC COUNTY Christopher Chan; Michael Devine; Gabriel : Escobar; Robert Espinosa; Robert Hintzen; Andrew Kara; John W. LaDuca; Tom Miller; James Mullin; John J. Paletto; Denise Ryaby; : DOCKET NO. L-004128-17 James Smith; Christopher Sullivan; Sara Toro; : and Stan Tovbin = CIVIL ACTION Plaintiffs, vs. : COMPLAINT Michael Saudino, individually, and in his official: (with Jury Demand) capacity as Bergen County Sheriff; the Bergen County Sheriff"'s Office; the County of Bergen; and the Bergen County Prosecutor's Office Defendants, Plaintiffs, Victoria Alberto, John Baker, Pete Bongiovanni, Alan Brundage, Robert Camey, Frank Carraficllo, Christopher Chan, Michael Devine, Gabriel Escobar, Robert Espinosa, Robert Hintzen, Andrew Kara, John W. LaDuca, Tom Miller, James Mullin, John J. Paletto, Denise Ryaby, James Smith, Christopher Sullivan, Sara Toro and Stan Tovbin (“Plaintiffs”), by way of Complaint against Defendants, Michael Saudino, individually, and in his official capacity as Bergen County Sheriff (“Saudino”); the Bergen County Sheriff's Office (“BCSO"); the County of Bergen (the “County”) (hereinafter collectively referred to as “Defendants”); and Defendant, the Bergen County Prosecutor's Office (“BCPO”), respectively say: ‘THE PARTIES 1. Atal times relevant hereto, Plaintifis were employed as police officers with the County in the Bureau of Police Services of the BCSO. Matthew A. Peluso, Esq. (#035721991) 103 Carnegie Center Suite 300 Princeton, NJ 08540 (609)306-2595 Counsel for Plaintiffs toria Alberto; John Baker; Pete Bongiovanni; SUPERIOR COURT OF NEW JERSEY Alan Brundage; Robert Camey; Frank Carrafiello; LAW DIVISION-PASSAIC COUNTY Christopher Chan; Michael Devine; Gabriel : Escobar: Robert Espinosa; Robert Hintzen: Andrew Kara; John W. LaDuca; Tom Miller: James Mullin; John J. Paleito; Denise Ryaby; DOCKET NO. L- James Smith; Christopher Sullivan; Sara Toro; and Stan Tovbin CIVIL ACTION Plaintiffs, vs. q COMPLAINT Michael Saudino, individually, and in his official: (with Jury Demand) capacity as Bergen County Sheriff; the Bergen County Sherif?’s Office; the County of Bergen; and the Bergen County Prosecutor's Office Defendants. Plaintiffs, Victoria Alberto, John Baker, Pete Bongiovanni, Alan Brundage, Robert Carney, Frank Carrafiello, Christopher Chan, Michael Devine, Gabriel Escobar, Robert Espinosa, Robert Hintzen, Andrew Kara, John W. LaDuca, Tom Miller, James Mullin, John J. Paletto, Denise Ryaby, James Smith, Christopher Sullivan, Sara Toro and Stan Tovbin (“Plaintiffs”), by way of Complaint against Defendants, Michael Saudino, individually, and in his official capacity as Bergen County Sheriff (“Saudino”); the Bergen County Sheriff's Office (“BCSO”); the County of Bergen (the “County”) (hereinafter collectively referred to as “Defendants”); and Defendant, the Bergen County Prosecutor's Office (“BCPO”), respectively say: ‘THE PARTIES 1, Atall times relevant hereto, Plaintiff were employed as police officers with the County in the Bureau of Police Services of the BCSO. 2. Plaimtiffs, Robert Hintzen and James Smith reside in the County of Passaic. Therefore, venue in this court is established by virtue of their residency in Passaic County pursuant to R. 4:3- 2(a), and in accordance with R. 4:3-3(a)(2), since blatant and irreconcilable personal and professional conflicts exist between Saudino and other employees of the County, BCSO and BCPO, all of whom have engaged in acts of retaliation against Plaintiffs in violation of CEPA as set forth infra, and ‘numerous sitting judges of the Superior Court of New Jersey, Bergen County, as the result of direct working relationships developed ona daily basis for years, including, inter alia, Sheriff officers’ daily ‘work assignments in all of the courtrooms in the Superior Court of New Jersey, Bergen County and the appearances and work of Bergen County Prosecutors before those judges on behalf of Defendant, the BCPO. 3. At all times relevant hereto, Saudino was employed by the County as the Sheriff of the County, in accordance with Article IIl, Section 2, paragraph 2 of the New Jersey Constitution, and, thus, had, inter alia, the highest command rank in the BCSO and supervisory authority over Plaintiffs at the County following the realignment of the former Bergen County Police Department with the BCSO in 2015, including, but not limited to, the authority to assign, discipline, demote and terminate Plaintiffs. 4. Atall times relevant hereto, the County is, and was, a governmental entity located in Hackensack, New Jersey, and was, with the BCSO, the employer of Plaintiffs as that term is defined under the Conscientious Employee Protection Act (“CEPA”), N.J.S.4. 34:19-1, ci, seg., and oversaw and controlled various administrative functions of the County and BCSO, and its agent Saudino, and other employees and agents of the County and BCSO, and was the employer of Plaintiffs as that term is defined under CEPA. 5. Atall times relevant hereto, Defendant, the BCSO is, and was, a department of the County located in Hackensack, New Jersey and was, with the County, the employer of Plaintifis as that term is defined under CEI ‘A, and oversaw and controlled various administrative functions of the 2