john j. hoffman acting attorney general of … · john j. hoffman acting attorney general of new...

JOHN J. HOFFMAN

ACTING ATTORNEY GENERAL OF NEW JERSEYR.J. Hughes Justice Complex25 Market Street

P.O. Box 116

Trenton, New Jersey 08625Attorney for DefendantsRaymond P. Martinez

New Jersey Motor Vehicle CommissionJohn Jay Hoffman, Esq.

State of New Jersey

Natasha Johnson

Department of Human Services, Divisionof Family Development, Office of

Child Support Services

By: Shana Bellin (907512012)

Deputy Attorney General

609-292-8565

[email protected]

ANDREANA KAVADAS, ALISHA

GRABOWSKI, LAQUAY DANSBY, and

PAULO AREDE,

Plaintiffs,

v.

RAYMOND P. MARTINEZ, JOHN J.HOFFMAN, ESQ., NATASHA JOHNSON,

and the DEPARTMENT OF HUMAN

SERVICES, DIVISION OF FAMILY

DEVELOPMENT, OFFICE OF CHILDSUPPORT SERVICES,

Defendants.

SUPERIOR COURT OF NEW JERSEY

LAW DIVISION - MERCER COUNTY

Docket No. MER-L-1004-15

CIVIL ACTION

OBJECTIONS AND RESPONSES TO

REQUESTS FOR ADMISSIONS ON

BEHALF OF DEFENDANTS.

DEFENDANTS' RESPONSES TO PLAINTIFFS' REQUESTS FOR

ADMISSIONS

Defendants Raymond P. Martinez, John J. Hoffman, Esq., NatashaJohnson, and the Department of Human Services, Division of FamilyDevelopment (hereinafter, "Defendants") object to any definitions,instructions and requests set forth in Plaintiffs' discoveryrequests to the extent they impose obligations beyond thoserequired by the New Jersey Rules, or seek information protected by

any privilege or protection from discovery including withoutlimitation the attorney-client privilege, common interest

privilege, and/or attorney work product protection. Subject to theforegoing, Defendants respond as follows.

The following responses are made solely for the purposes of

this action. Each response is subject to all objections as to

relevance, materiality, and admissibility, and to any and all

objections on any ground that would require exclusion of anyresponse if it were introduced in court.

No incidental or implied admissions are intended by these

responses. The fact that Defendants have objected or responded toany request shall not be deemed an admission that Defendants accept

or admit the existence of any facts set forth or assumed by such

request or that such objection or response constitutes admissible

evidence. The fact that Defendants have responded to part or all of

any request is not intended to and shall not be construed to be a

waiver by Defendants of any part of any objection to any request.

The responses and objections are made on the basis of

information and writings currently available to and located by

Defendants upon reasonable investigation. Defendants expressly

reserve the right to modify, revise, supplement, or amend their

responses as they deem appropriate. The word usage and sentence

structure contained in the Discovery responses may be that of the

attorney assisting in the preparation of the answers and thus, does

not necessarily purport to be the precise language of the executing

party.

1. Admitted that Plaintiffs have been in arrears on child

support orders issued by the Superior Court of New Jersey.

Defendants are without sufficient information to form a belief

as to the truth or allegations of the remainder of the

paragraph.

2. Defendants object to the use of the term "facing". The

term "facing" is not defined or placed in any context and is

therefore ambiguous. Thus, Defendants can neither admit nor

deny.

3. Admitted that Raymond P. Martinez is the Chief

Administrator of the New Jersey Motor Vehicle Commission

("MVC") Denied as to the remainder of the allegations of

this paragraph.

4. This request asserts a question of law and accordingly no

response is given.

5. Denied that Chief Administrator Raymond P. Martinet's

personal duties include suspending and reinstating driver's

licenses.

6. Admitted.


response is given.

8. Admitted that John Jay Hoffman's duties include acting as

New Jersey's chief law enforcement officer and legal advisor.

Denied that John Jay Hoffman is responsible for the management

and administration of the Division of Law.

9. Admitted.


response is given.

11. Denied.

12. Defendants object to the term "stated intent".

Plaintiffs do not indicate the source upon which stated the

intent for purposes of this paragraph. The term is therefore

ambiguous. This request asserts a question of law and

accordingly no response is given.

13. Defendants object to this request to the extent that it

is argumentative, prejudicial, improper, incorrect, and

ambiguous. Defendants object to the use of the term

"protectable" as undefined, out of context and therefore

ambiguous. Defendants object to the use of the term "license"

as it is ambiguous, and does not refer to a specific type of

license. This request asserts a question of law and


14. Defendants object to the use of the term "progeny" as it

is undefined and out of context and therefore ambiguous. This

request asserts a question of law and accordingly no response

is given.


is argumentative and calls for a legal conclusion.

Accordingly, no response is given.


is argumentative and calls for a legal conclusion. Defendants

object to the use of the term "license" as undefined, out of

context and therefore ambiguous. Accordingly, no response is

given.

17. Defendants object to this request as it is argumentative

and calls for a legal conclusion. Defendants object to the

use of the term "license" as undefined, out of context and

therefore ambiguous. Accordingly, no response is given.

18. Request #18 does not exist.

19. Defendants deny to the extent that this request implies

that "probation" invariably schedules an ELR hearing upon

every initial default on every child support order lasting at

least 14 days. Defendants object to this request as it is not

directed at these defendants and/or to information in their

possession or control.

20. Defendants object to the use of the included statistic as

undefined, out of context, and argumentative. Defendants

further object to this request to the extent that it

interprets an order of the Administrative Office of the Courts

and therefore is a question of law. Defendants are without

sufficient information to admit or deny.

21. Defendants object to the phrases "Two week warrant

status" as undefined and "believe...necessary" and as out of

context and therefore ambiguous. Defendants further object on

the basis that this request calls for a legal conclusion.

Defendants further object to this request as it is not


possession or control. Accordingly, no response is given.


calls for a legal conclusion. Defendants object to the phrase

"there is no equitable reason...with the child support order"

as out of context and therefore ambiguous. Defendants further

object to this request as it is not directed at these

defendants and/or to information in their possession or

control. Accordingly, no response is given.


is not likely to lead to the discovery of admissible evidence.

Defendants object to the use of the terms "specific inquiry",

"hearing" and "license" as undefined, out of context and

therefore, ambiguous. Defendants further object to this

request as it is not directed at these defendants and/or to

information in their possession or control. Without more

information, Defendants are without sufficient information to

admit or deny.





therefore ambiguous. Defendants further object to this


information in their possession or control. Denied that

plaintiff Alisha Grabowski has had a driver's license

suspended in the State of New Jersey. Subject to and without

waiving the foregoing objections, Defendants are without

sufficient information to admit or deny.







information in their possession or control. Subject to and

without waiving the foregoing objections, Defendants are

without sufficient information to admit or deny.








without waiving the foregoing objections, Defendants are

without sufficient information to admit or deny.


is duplicative. Defendants further object to this request as

it is not directed at these defendants and/or to information

in their possession or control. See response to Request #22.


28. Defendants object to the use of the terms "expire" and

"two week warrant stipulation" as undefined, out of context

and therefore, ambiguous. Defendants further object to this


information in their possession or control. Accordingly, no

response is given.

29. Defendants object to the use of the terms "warrant" and

"automatic suspension" as undefined, out of context and

therefore, ambiguous. Subject to and without waiving the

foregoing objections, Defendants deny.

30. Defendants object to this request as vague and ambiguous

as Plaintiffs have not established to which Directive they are

referring. Defendants note that Plaintiffs have referred to

Directive 3115-08 and Defendants are without knowledge of any

such Directive. Defendants object to the use of the terms

"additional", "notice", "warrant" and "license" as undefined,

out of context and therefore, ambiguous. Defendants further

object to this request on the basis that it calls for a legal

conclusion. Defendants further object to this request as it

is not directed at these defendants and/or to information in

their possession or control. Accordingly, no response is

given.

31. Request #31 does not exist.





such Directive. Defendants object to the use of the terms

"additional", "hearing", "default", "stipulation", "warrant"

and "license" as undefined, out of context and therefore,

ambiguous. Accordingly, no response is given.

33. No request exists for #33.





such Directive. Defendants object to this request as

prejudicial, improper, irrelevant and argumentative and

calling for a legal conclusion. Defendants object to the use

of the terms "warrant" and "ability to comply" as undefined,

out of context and therefore, ambiguous. Accordingly, no

response is given.


36. Defendants object to this request as not likely to lead

to the discovery of admissible evidence, prejudicial,

improper, and argumentative and calling for a legal

conclusion. Defendants object to the use of the terms

"evidence" and "alone as undefined, out of context, and




without waiving the foregoing objections, Defendants deny.





such Directive. Defendants object to this request as

prejudicial, improper, not likely to lead to the discovery of

admissible evidence, argumentative and calling for a legal

conclusion. Defendants object to the use of the terms

"hearing", "license", and "coercive effect" as undefined, out

of context and therefore, ambiguous. Defendants further





39. Defendants object to the use of the terms "notice" and

"license", and the phrase "all orders entered following ELR

hearings" as overly broad and therefore ambiguous. Defendants

further object to this request as it is not directed at these


control. Subject to and without waiving the foregoing

objections, Defendants admit that some documents issued by the

Probation Division following ELR hearings contain warnings of

consequences for failure to comply.

40. Defendants object to the use of the terms "notices" ,

"necessity", "modification" and "application", and the phrase

"change in circumstances" as overly broad, undefined and out

of context, and therefore ambiguous. Defendants further




objections, Defendants admit that some documents issued by the

Probation Division contain information regarding modification

of child support orders.

41. Defendants object to the use of the terms "such notices",

"support obligation" and "license" as undefined and out of

context and therefore ambiguous. Defendants further object to

this request as it is not directed at these defendants and/or

to information in their possession or control. Subject to and

without waiving the foregoing objections, Defendants admit

that Plaintiffs received some documents regarding the

possibility of license suspension from certain offices.

42. Defendants object on to this request on the basis that it

is an incomplete representation of the text of the Uniform

Standard Support Order ("USSO") Provision 13 of the USSO

states, in part, that a driver's license held or applied for

by an obligor

shall be denied, suspended, or revoked ifthe court issues a warrant for theobligor's arrest for failure to pay childsupport as ordered, or for failure toappear at a hearing to establishpaternity or child support, or forfailure to appear at a child supporthearing to enforce a child support orderand said warrant remains outstanding. (R.

USSO, Provision No. 13.

Defendants further object to the use of the terms

"license", "default" and "all orders entered following an ELR

hearing" as undefined, overbroad, vague and ambiguous.



possession or control. Subject to and without waiving the

foregoing objections, Defendants admit to the extent that the

USSO provides notice that a driver's license suspension is a

possible result of a failure to comply with a child support

order.

43. Defendants object to the use of the term "all orders

entered following ELR hearings" as undefined, overly broad,

vague and therefore ambiguous. Defendants further object to


to information in their possession or control. Subject to and


that Paragraph 2 of the USSO contains the stated information.

Otherwise, denied.

44. Defendants object to this request as argumentative,

incomprehensible, improper and as calling for a legal

conclusion. Accordingly, no response is given.

45. Defendants object to this request as convoluted, vague,

argumentative and calling for a legal conclusion.


46. Defendants object to this request as vague. Plaintiffs

do not define "the process" nor the "difference" alleged.


47. Defendants object to this request as vague, ambiguous,

prejudicial, improper, argumentative and calling for a legal

conclusion. Accordingly, no response is given.

48. Admitted.

49. Defendants object to this request as argumentative. The

call of the question implies that the motion's denial must

have been made with consideration for the factors alleged in

this paragraph, which are out of context and accordingly

objected to as ambiguous. Defendants object to the use of the

term "license" as vague, out of context and therefore,

ambiguous. Defendants object to the term "that motion" as

Plaintiffs have not indicated any particular motion. The

application referred to in Request #48 refers to "at least one

application", and does not further specify. Defendants



control. To the extent that Plaintiffs are referring to the

August 29, 2014 Order executed by Hearing Officer Nancy Coyle,

denied. With respect to any other motions Plaintiffs possibly

are referring to, Defendants object to this request as overly

broad and accordingly no response is given.

50. To the extent that Plaintiffs rely on the August 29, 2014

Order, Defendants object to this request as Plaintiffs quote

portions of the August 29, 2014 Order out of context and

therefore the request is ambiguous. Defendants object to this

request on the basis that it is ambiguous as it does not refer

to the specific motion that was allegedly denied. Subject to

and without waiving the foregoing objections, Defendants admit

that one of Plaintiff Andreana Kavadas's motions was denied on

August 29, 2014, and that Hearing Officer Nancy Coyle made the

finding on that date that $40 per week was a "minimal", among

other findings. Defendants further state that Hearing Officer

Nancy Coyle's recommendations were adopted by the court and

approved by the Hon. Peter Tober.

51. Defendants object to this request as vague and ambiguous,

as Plaintiffs do not indicate which court made a finding, or

on what date, or about whom. To the extent that Plaintiffs

rely on the August 29, 2014 Order, issued by Hearing Officer

Nancy Doyle to Plaintiff Andreana Kavadas, Defendants further

object to this request on the basis that it calls for

speculation as to the entire reasoning behind the hearing

officer's findings. Accordingly, no response is given.

52. Defendants object to the use of the term "subsequently~~

as undefined. Defendants further object to this request on

the basis that it implies that an indefinite amount of time

passed before Plaintiff Andreana Kavadas's driver's license

was allegedly suspended and does not provide the date of that

suspension. Subject to and without waiving the foregoing

objections, Defendants admit that Plaintiff Andreana Kavadas

had her driver's license suspended at one point.

53. Defendants object to this request as vague and ambiguous.

Defendants object to the use of the term "two week warrant

status" as undefined and therefore ambiguous. Subject to and


that Plaintiff Paulo Arede filed at least one application to

have support modified. Without a definition of "two week

warrant status", Defendants can neither admit nor deny.

54. Defendants object to this request as vague and ambiguous.

Defendants further object to this request as argumentative, as

it implies that a consideration as to whether "there is [any]

... non-compliance with the child support order" is a

requirement prior to the suspension of a driver's license.

Defendants further object to the use of the term "license" as

vague and out of context and therefore ambiguous. Plaintiffs

refer to "that motion" without setting forth any foundation

specifying the motion to which they are referring. Thus,

Defendants can neither admit nor deny.

55. Defendants object to this request as out-of-context and

without proper supporting foundation or primary evidence.

Defendants further object to this request as not likely to

lead to the discovery of any admissible evidence. Defendants



control. Subject to the foregoing objections, Defendants

admit that Arede receives SSI.

56. Defendants object to the use of the terms "subsequently"

and "license" as vague and out of context and therefore

ambiguous. Defendants further object to this request on the

basis that it implies that an indefinite amount of time passed

before Plaintiff Paulo Arede's license was allegedly suspended

and does not provide the date of that suspension. Subject to

and without waiving the foregoing objections, Defendants admit

that Plaintiff Paulo Arede's driver's license was suspended on

at least one occasion.

57. Defendants object to this request as out of context and





that a court has imputed income to Plaintiff Paulo Arede.

58. Defendants object to this request as overly broad, vague

and ambiguous. Specifically, the words "currently actually

has funds available" is vague and ambiguous as "currently" is

not defined and "funds" and "available" are unclear.




foregoing objections, Defendants have insufficient information

to admit or deny.

59. Defendants object to this request as vague and therefore

ambiguous. Plaintiffs have not specified the motion that they

refer to in this request. Defendants further object to this




that Plaintiff Andreana Kavadas has filed a motion to adjust

her support obligation on at least one occasion.

60. Defendants object to this request on the basis that it is

argumentative and calls for a legal conclusion. Defendants

further object to the use of the term "license" as vague and

out of context, and therefore ambiguous. Defendants further

object to the use of the term "obligor" as undefined.



convoluted, argumentative and calls for a legal conclusion.

Defendants further object to the use of the term "license" as

vague and ambiguous, "coercive" as undefined and out of

context and therefore ambiguous, and "modification of an

order" as vague and out of context and therefore ambiguous.


62. Admitted.


overly broad and the use of the terms "order", "source rule"

and "provision" as undefined. Defendants further object to


to information in their possession or control. Accordingly,

no response is given.

64. Defendants object to this request on the basis that it

calls for a legal conclusion. Defendants further object to




65. Defendants object to the use of the phrase "none of the

notices provided" as vague and ambiguous. Defendants object

to the use of the term "license" and "obligor" as vague,

undefined, out of context and therefore ambiguous. Defendants

further object to this request as argumentative and calling

for a legal conclusion. Accordingly, no response is given.





such Directive. Defendants object to the use of the term

"obligor" as undefined, and the terms "specific notice" and

"imminent" as undefined, vague and out of context and


request on the basis that it calls for a legal conclusion.



68. Defendants object to the term "notices" as undefined and

the phrase "at various times, sometimes every month and

sometimes not for six months" as overly broad, vague and

therefore ambiguous. Subject to and without waiving the

foregoing objections, Defendants admit that Plaintiffs

Andreana Kavadas, Alisha Grabowski, and LaQuay Dansby received

notices.

69. Defendants object to the terms "any such" and "warning

notice" as undefined, out of context and therefore ambiguous.




70. Defendants object to this request as argumentative and

calling for a legal conclusion and object to the term

"counterproductive" as undefined and ambiguous. Defendants




71. Defendants object to this request as overly broad and

calling for proof of a negative. Defendants further object to


to information in their possession or control. Defendants are

without sufficient information to either admit or deny.


72. Defendants object to the use of the terms "coercive

action" and "justified" as undefined and therefore ambiguous.

Defendants further object to this request on the basis that it

calls for a legal conclusion. Accordingly, no response is

given.




to information in their possession or control. Defendants are

without sufficient information to either admit or deny.



calls for a legal conclusion and object to the terms

"essentially" and "as set forth herein" as undefined and

therefore ambiguous. Accordingly, no response is given.



the terms "the process", "provided", "default", "warrant" and

"license" as undefined and therefore ambiguous. Defendants






given.


refers to an undefined document and seeks to paraphrase the

conclusions set forth in that document without sufficient

bases. Defendants further object to this request as it is not



78. Defendants object to the use of the term "many studies".

Defendants further object to this request on the basis that it

is unlikely to lead to the discovery of admissible evidence.



possession or control. Without knowing the universe of

studies Plaintiffs refer to, Defendants do not have sufficient

information to admit or deny and accordingly no response is

given.







sets forth statistics without providing the source for those

statistics. Defendants further object to this request as it


their possession or control. Without knowing the source upon

which Plaintiffs rely for these statistics, Defendants are

without sufficient information to admit or deny and



sets forth statistics without providing the source for those

statistics. Defendants further object to this request as it


their possession or control. Without knowing the source upon

which Plaintiffs rely for these statistics, Defendants are

without sufficient information to admit or deny and



calls for opinion and speculation and not fact and is a

question of law. Defendants further object to this request as


in their possession or control. Accordingly, no response is

given.


calls for opinion and speculation and not fact. Defendants





unlikely to lead to the discovery of admissible evidence and

because it calls for speculation. Defendants further object

to this request as it is not directed at these defendants

and/or to information in their possession or control.



calls for a legal conclusion and opinion. Defendants further

object to the use of the terms "reasonably" and

"contemporaneous" and "erroneous deprivation" as undefined,






unlikely to lead to the discovery of admissible evidence.











given.



given.

90. Admitted that Plaintiffs have made this allegation in

their Complaint.


calls for a legal conclusion. Defendants also object to the

US2 Of the terms "notice" , "current system" , and ~~ OI7US ~~ dS

undefined, vague and therefore ambiguous. Defendants further






given.



given.

94. Defendants object to this request as incomprehensible.






given.



given.



given.



given.





















103. Admitted that N.J.S.A. 2A:17-56.41 contains this

language. Denied that this language constitutes the full text

of the statutory provision.

104. Defendants object to the use of the terms "warrant,"

"define" and "issue" as undefined, out of context and

therefore ambiguous. Defendants further object on the basis

that this request calls for a legal conclusion. Defendants




objections, Defendants deny.






106. Admitted.

107. Defendants object to the use of the terms "warrant",

"issue", "default" and "child support order" as undefined, out

of context and therefore ambiguous. Defendants are without

sufficient knowledge to admit or deny and accordingly, no

response is given.


vague. Defendants further object to the use of the terms

"specific court rule", "warrant", "issue", "default" and

"child support order". Defendants further object to this

request on the basis that it calls for a legal conclusion.




















calls for a legal conclusion. Defendants further object on

the basis that there are unaware of any directive titled

Directive #11315-08 and object to the use of the terms

"warrant", "cause" and "internal" as undefined, vague and




response is given.




the basis that they have no knowledge of any directive titled

Directive #1515-08. Defendants further object to the use of

the terms "warrant", "license" and "default" as undefined,








the basis that they have no knowledge of any directive titled

Directive #11715-08. Defendants further object to the use of

the terms "warrant", "license" and "default as undefined,












calls for a legal conclusion. Defendants further object as

they have no knowledge of any directive titled Directive

#12015-08. Accordingly, no response is given.




the use of the terms "this section" as undefined and therefore

ambiguous. Defendants further object to this request as it is

not directed at these defendants and/or to information in


given.


calls for a legal conclusion. Defendants further object

because they are without knowledge of any directive titled

Directive # 12315-08. Defendants further object to this



response is given.




















the use of the term "reasonably contemporaneous" as undefined,





133. Admitted.












141. No request for #141 exists.


calls for a legal conclusion. Defendants further object

because they are without knowledge of any directive titled

Directive #14115-08. Defendants further object to this



response is given.

143. Defendants object to the use of the terms "promulgation",

"the Directives" and "public process" as undefined, out of

context and therefore ambiguous. Defendants further object to

the request on the basis that it calls for a legal conclusion.








such Directive. Defendants further object to this request as



given.









given.





Directives 14902-04, 15018-06 and 15115-08. Defendants are

without knowledge of any such Directives. Defendants further














given.





Directives 15502-04, 15618-06 and 15715-08, and Defendants are

without knowledge of any such Directives. Defendants further







158. Defendants object to use of the phrase "are subject" and

the term "'two week warrant status' orders" as undefined,

vague and out of context. Defendants further object to this

request on the basis that it is overly broad. Defendants




159. Admitted.

160. Defendants object to the use of the terms "two week

warrant status" as undefined and the phrase "since 2007" as

out of context and therefore ambiguous. Defendants further




161. Defendants object to the use of the terms "hearing" and

"factors set forth in N.J.S.A. 2A:17-56.43(5)(a)" as

undefined, out of context and therefore ambiguous. Defendants

further object to this request as calling for speculation and

not fact. Defendants further object to this request as it is



given.

162. Defendants object to the use of the terns "license",

"suspended" and "issuance of a warrant" as undefined, out of

context, vague and therefore ambiguous. Subject to and


that Plaintiffs Kavadas, Arede and Dansby have had their

driver's license suspended on at least one occasion due to the

issuance of a bench warrant.

163. Defendants object to the use of the terms "most recent",

"written notice", "probation", and "warrant" as undefined,

overly vague, and therefore ambiguous and misleading.

Defendants are without sufficient knowledge to either admit or

deny this request. Defendants further object to this request

as it is not directed at these defendants and/or to


response is given.

164. Defendants object to the use of the terms "most recent",

"written notice", and "prior to that" as undefined, overly

vague, and therefore ambiguous and misleading. Defendants are

without sufficient knowledge to either admit or deny this

request. Defendants further object to this request as it is



given.


calls for a legal conclusion. Defendants reiterate their

objections to requests #163 and #164. Accordingly, no

response is given.


calls for a legal conclusion. Defendants reiterate their

objections to requests #163 and #164. Accordingly, no

response is given.

167. Defendants object to the use of the term "notices" as

overly vague, undefined and broad and therefore ambiguous.


168. Defendants object to the use of the term "contacted" and

"motion" as overly broad, vague, undefined and therefore

ambiguous. Defendants object to the assertion that Plaintiff

Kavadas filed a motion as a result of contacting customer

service as calling for speculation. Defendants further object

to this request as it is not directed at these defendants

and/or to information in their possession or control. Subject

to and without waiving the foregoing objections, Defendants

are without sufficient information to admit or deny and


169. Defendants further object to this request as it is not



170. Defendants object to the use of the term "two week

warrant status" and the phrase "since 2009" as out of context

and therefore ambiguous. Defendants further object to this



response is given.

171. Defendants further object to this request as it is not


possession or control. Defendants are without sufficient

information to either admit or deny.

172. Admitted that a court has imputed income to Plaintiff

Paulo Arede on at least one occasion.


calls for speculation. Defendants admit that a court has

found that Arede has an ability to pay his child support

obligation.


incomprehensible and calls for a legal conclusion.







response is given.


vague. Defendants further object to the use of the term

"indigent" as undefined, out of context and therefore

ambiguous. Defendants further object to this request as it is



given.






response is given.


vague. Defendants further object to this request as it is

unclear as to the time frame. Accordingly, no response is

given.


vague. Defendants further object to this request as it is

unclear as to time frame. Accordingly, no response is given.


vague. Defendants further object to the use of the term

"warrant" as undefined and out of context and therefore

ambiguous. Defendants further object to this request as it

calls for speculation. Defendants further object to this



response is given.


calling for proof of a negative. Defendants also object to

the use of the term "imminent" as undefined, out of context




without waiving these objections, Defendants admit that

Plaintiffs received numerous notices that their driver's

licenses may be suspended if their child support is in

arrears.



this request on the basis that it calls for a conclusion of

law. Accordingly, no response is given.

183. Denied. 42 U.S.C. 666(a)(16) states, in whole:

Authority to withhold or suspend licenses.—

Procedures under which the Sate has (and

uses in appropriate cases) authority to

withhold or suspend, or to restrict the use of

driver's licenses, professional and

occupational licenses, and recreational and

sporting licenses of individuals owing overdue

support or failing, after receiving

appropriate notice, to comply with subpoenas

or warrants relating to paternity or child

support proceedings.



given.



given.



given.



given.



given.



given.


calls for an opinion and a legal conclusion. Defendants










calling for proof of a negative. Defendants are without

sufficient information to either admit or deny. Defendants




193. Defendants object to the terms "enforcement process",

"facing incarceration" and "indigent" as undefined, overly

vague, and therefore ambiguous. Defendants further object on

the basis that this request calls for proof of a negative.




foregoing objections, Defendants admit that LaQuay Dansby had

counsel appointed to him in 2014 by the Honorable Catherine

Fitzpatrick, P.J.F.P.

194. Defendants object to the terms "means-tested benefits" and

"VATIC" as undefined and therefore ambiguous. Defendants




195. Defendants object to the terms "means-tested benefits" and

"SSI" as undefined and therefore ambiguous. Defendants




196. Defendants object to the terms "indigent", "Ability to

Comply hearing" and "faced incarceration" as overly broad,

vague, undefined and therefore ambiguous. Defendants further





calls for an opinion and a legal conclusion. Accordingly, no

response is given.



given.


calls for an opinion and a legal conclusion. Accordingly, no

response is given.



given.



given.























further object to the use of the term "those conditions" as

undefined vague and therefore ambiguous. Defendants further
















further object to the use of the term "above steps" as

undefined, vague and therefore ambiguous. Defendants further





relies on statistics without laying a foundation or stating a

source for the statistic. Without the foundation or source,

Defendants are without sufficient information to admit or

deny. Defendants further object to this request as it is not





this request to the extent that it calls for a legal

conclusion. Defendants further object to this request as it


their possession or control. Defendants are without

sufficient information to either admit or deny. Accordingly,


212. Defendants object to this request as calling for

speculation. Defendants further object to this request to the

extent that it calls for a legal conclusion. Defendants



control. Defendants are without sufficient information to

either admit or deny. Accordingly, no response is given.

213. Defendants object to this request as incomprehensible,

argumentative and convoluted. Defendants further object to

this request to the extent that it calls for a legal

conclusion. Subject to and without waiving the foregoing

objections, denied.

JOHN J. HOFFMAN

ACTS ATTORNEY GENERAL OF NEW JERSEY

~i:.l~i~~<<~S Be~IlinDe ty Attorney General

DATED: ~ ~ /

john j. hoffman acting attorney general of … · john j. hoffman acting attorney general of new...

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