Charges Narrowed in Former Township Clerk's Complaint Against Galloway

Each defendant in Lisa Tilton’s lawsuit against Galloway Township now knows specifically what he or she is being charged with.

In response to a request to clarify the 86-page lawsuit, Tilton’s attorney, Steven Srenaski, filed a “More Definite Statement of the Complaint,” on Wednesday, Oct. 17. He had 20 days from the time he was asked to clarify the complaint on Sept. 28 to do so. Attorneys Daniel Baylson and Michael Barker, representing the various defendants in the case, now have 20 days from Oct. 17 to file their responses.

Baylson’s client, former Township Solicitor Michael Blee, is named in four of the 27 counts. All charges naming Blee and his law firm allege violations of the identity theft prevention act, the publication of private facts, the violation of the fundamental right to privacy and negligence.

The accusations center around the alleged release of Tilton’s personal information to Martin O’Boyle, a third party not directly involved in the situation who was requesting documents pertaining to Tilton’s publicly reported suspension and dismissal from her position as Township Clerk.

Tilton alleges that in this case, and in numerous other situations, the township, under Blee’s supervision, repeatedly released Tilton’s information to various members of the public. These charges are addressed in Counts 19, 20, 21 and 22 of the complaint.

The charges are also the subject of counts seven, eight and nine, but Blee and his law firm are not named in these counts. Township Clerk Thalia C. Kay, Registrar of Vital Statistics Carol Hackney and former deputy clerk Karen Bacon are named.

These three, and all other defendants in the case, with the exception of former Township Manager Steve Bonanni, are represented by Barker. Bonanni will be represented by Mike Madden.

The sides also have a mediation scheduled for Nov. 8.

The 11-page clarification states explicitly who is charged with which charges:

• Count One, dealing with discrimination, sexual harrassment and a hostile work environment, specifically charges Galloway Township; former Township Manager Steve Bonanni; Former Councilman Dennis Kleiner; Mayor Don Purdy; Deputy Mayor Tony Coppola; and council members Tom Bassford, Jim Gorman, Brian Tyrrell and Whitney Ullman;
• Count Two, charging intentional infliction of emotional distress, specifically charges the township and Bonanni;
• Counts Three and Four, dealing with the violation of freedom of speech and association, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count Five, alleging violation of free speech and petition, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count Six, alleging attempted interference and deprivation of rights secured by state law, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count Seven, alleging a violation of the fundamental right to privacy, specifically charges: Township Clerk Thalia C. Kay; Registrar of Vital Statistics Carol Hackney; former deputy clerk Karen Bacon; the township; Bonanni; Bassford; Coppola; Gorman; Kleiner; Purdy; Tyrrell; and Ullman;
• Count Eight, which covers Open Public Records Act (OPRA) violations, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell, Ullman, Bacon, Hackney and Kay;
• Count Nine, charging false light/libel, per se, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell, Bacon Hackney and Kay;
• Count 10, alleging discrimination, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 11, alleging constructive discharge in violation of  public policy, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 12, alleging violation of the state conscientious employee protection act, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 13, alleging malicious prosecution, specifically charges the township and Kleiner;
• Count 14, alleging a violation of the right to liberty, specifically charges the township and Kleiner;
• Count 15, dealing with the rescission of settlement and release agreement, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell, Ullman, Bacon, Hackney and Kay;
• Count 16, dealing with defamation and slander, specifically charges the township and Kleiner;
• Count 17, alleging attempted intimidation and interference of rights secured by state law, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy,Tyrrell and Ullman;
• Count 18, alleging false light, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy Tyrrell and Ullman;
• Count 19, alleging violations of the state identity theft prevention act, specifically names Blee, the Blee Law Office, 10 unnamed John Does, the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 20, alleging negligence, specifically charges Blee, Blee Law Office, 10 unnamed John Does, the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 21, alleging the publication of private facts, specifically charges Blee, Blee Law Office, 10 unnamed John Does, the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 22, alleging violation of fundamental right to privacy, specifically charges Blee, Blee Law Office, 10 unnamed John Does, the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 23, alleging negligent supervision, specifically charges the township, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 24, alleging inadequate training, supervision and promulgation of policies, customs and practices in violation of the state’s civil rights act, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 25, dealing with vicarious liability, specifically charges the township, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman;
• Count 26, dealing with civil conspiracy to intimidate, interfere and deprive plaintiff of civil rights, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell and Ullman; and
• Count 27, dealing with civil conspiracy to commit unlawful retaliation, specifically charges the township, Bonanni, Bassford, Coppola, Gorman, Kleiner, Purdy, Tyrrell, Ullman, Bacon, Hackney and Kay.