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Zainab K. Ali Ali Law, PC 1601 Cherry Street, Suite 1320 Philadelphia, PA 19103 (267) 689-8481 zainab@alilawpc.com

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

______________________________________________

:

Keith Errol Benson, The Camden High School : Alumni Association of Camden, NJ A NJ Nonprofit : Corporation, Camden High School PTO LTD, : Mo

’N

eke Ragsdale, Leslie Proctor, Frank M. Ingram, : Civil Action No.: 1:17-CV-5439 Namibia El and Doris Carpenter : : Hon. ______________________ Plaintiffs, : : v. : COMPLAINT FOR DECLARATORY : AND INJUNCTIVE RELIEF New Jersey Schools Development Authority, : Charles McKenna, Executive Director, New : Jersey Schools Development Authority, : Camden City School District; Camden City Board of : Education, Paymon Rouhanifard, Superintendent : Camden City School District : : Defendants. : ______________________________________________________________________________ ______________________________________________________________________________

I.

INTRODUCTION

1.

Plaintiffs Keith Errol Benson, 1464 Belleview Avenue, Camden, New Jersey 08103, the Camden High School Alumni Association of Camden, NJ A NJ Nonprofit Corporation

(Hereinafter “Camden High Alumni Association”)

, 1775 Park Boulevard, Camden, New Jersey 08103, the Camden High School PTO LTD, 317 Clinton Street, Camden. New Jersey 08103,

Mo’N

eke Ragsdale, 317 Clinton Street, Camden, New Jersey 08103, Leslie Procter, 2836 Idaho Road, Camden, New Jersey 08104, Frank Ingram, 969 North 35

th

Street, Camden, New Jersey 08105, Namibia El, 1104 Carl Miller Boulevard, Camden, New Jersey

Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 1 of 14 PageID: 1

08104, and Doris Carpenter, 1736 Hillcrest, Avenue, Pennsauken, New Jersey 08110,

(collectively referred to as “Plaintiffs”) bring this acti

on against Defendants New Jersey School Development Authority, 1 West State Street in the City of Trenton, County of Mercer, State of New Jersey 08608, Charles McKenna, the Executive Director of the New Jersey School Development Authority, 1 West State Street in the City of Trenton, County of Mercer, State of New Jersey 08608, Camden City School District, 201 Front Street, Camden, New Jersey 08102, Camden City Board of Education, 201 Front Street, Camden, New Jersey 08102, and Paymon Rouhanifard, the state-appointed Superintendent of the Camden City School District, 201 Front Street, Camden, New Jersey 08102. 2.

Plaintiffs seek a declaratory order that the actions of the Defendants are unlawful and invalid, and seek injunctive relief barring Defendants from contracting for, commencing, allowing, permitting, advancing funds, for, or continuing demolition of the historic Camden High School unless and until such time as Plaintiffs have had meaningful opportunity to participate. 3.

Plaintiffs and other preservation organizations have repeatedly urged Defendants to refrain from demolishing the historic Camden High School until such time as there has been a fair and meaningful opportunity to be heard. 4.

By hastily proceeding with demolition of the historic Camden High School without releasing to the public any environmental impact studies, reports, plans, definitive or otherwise, for the demolition or construction of the replacement school,

Defendants’ sole purpose

is to evade public scrutiny and meaningful participation in violation of the Due Process Clause of the Fourteenth Amendment of the United States Constitution, as well as New Jersey statutory law.

II.

JURISDICTION AND VENUE

5.

Plaintiffs allege deprivation of rights secure by the Due Process Clause of the Fourteenth Amendment as protected by 42 U.S.C. § 1983, and 42 U.S.C. § 1988. Jurisdiction is invoked pursuant to 28 U.S.C. § 1331 and § 1343.


6.

Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b) on the grounds that Plaintiffs causes of actions arose in the District of New Jersey, some or all of the conduct at issue took place in, and all the Defendants are found in the District of New Jersey.

III.

PARTIES

7.

Plaintiff Keith Errol Benson is an individual and Alumnus of Camden High School with interest in the preservation of the history of and culture of Camden High School and in the preservation of the environmental safety of the immediate surrounding areas. He has strong interest in the preservation and re-use of the historic Camden High School, which is slated for demolition as result of the actions complained of herein. His address is 1464 Belleview Avenue, Camden, New Jersey 08103. 8.

Plaintiff Camden High Alumni Association is an organization with seven or more members and the capacity to sue and be sued in its own name. The non-profit corporation is composed of alumni of Camden High School with interest in the preservation of the history of and culture of Camden High School and in the preservation of the environmental safety of the immediate surrounding areas. It has strong interest in the preservation and re-use of the historic Camden High School, which is slated for demolition as result of the actions complained of herein. Its mailing address is 1775 Park Boulevard, Camden, New Jersey 08103. 9.

Plaintiff Camden High School PTO LTD is an organization with seven or more members and the capacity to sue and be sued in its own name. Its membership includes current and past parents and teachers of Camden High School students. It has strong interest in the preservation and re-use of the historic Camden High School, which is slated for demolition as result of the actions complained of herein. Its mailing address is 317 Clinton Street, Camden, New Jersey 08103. 10.

Plaintiff Mo’N

eke Ragsdale is an individual and Alumnus of Camden High School with interest in the preservation of the history of and culture of Camden High School and
