7/23/2019 TORT Notice Hodges Family

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Law

Offices

KEARNEY, CAMPBELL BURNS P.C.

JOHN B. KEARNEY

LINDA

L.

CAMPBELL

SCOTT D. BURNS*

*Member N.J. andP

Bars

}.{ember N.J., PA FL Bars

A Professional Corporation

21 0 White Horse Pike

Haddon Heights, N 08035

856) 54 7-7733

July

29

2015

Division of Child Protection Permanency

50 E. State Street

P.O. Box 717

Trenton, NJ 08625-0717

DCP P

309 Fries Mill Road

Echo Plaza, Unit 10

Sewell, NJ

Attn

Stephanie Lex, via fax 856 582-4065

CGS Family Partnership

445 Woodbury-Glassboro Road

Suite one Sewell,

NJ

Attn Dr. Bukola Ogunkua via facsimile 856-716-2109

Via

Certified

Mail RRR

Regular

Mail

Re: In the

Matter

of

Devon

Hodges

Fax (856) 546-5154

httn://www.nj law.com

Dear Division of Child Protection Permanency and CGS Family Partnership:

Please

be

advised that this office represents Valerie and Karl Hodges. The

couple adopted a child through DCP P, formerly DYFS. At the time the parties were not

told about the birth mother's extensive mental illness and drug abuse, or the maternal

grandmother's alcoholism and mental illness. The adoptive parents were not told about

the drug and alcohol abuse of the birth mother during her pregnancy. The adopted

parents were not told of the birth father's extensive drug

and

alcohol abuse

The child had

an

escalating pattern of severe mental illness culminating with the

child sexually assaulting his younger brother, (3-14-2015), attempting to kill his adoptive

father with a knife, (5-16-2015), and attempting

to

drown

his

sister in the pool, (6-7-

7/23/2019 TORT Notice Hodges Family

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2015). The child heard

and

hears voices that tell him to kill his family and kill and/or

injure his classmates.

The parents contacted DCP&P. The parents told DCP&P that they were afraid to

bring the child back into the house. DCP&P refused to help place the child in a secure

facility. DCP&P threatened criminal charges against my clients and to file a complairii in

DCP&P court and

to

drag my client's into DCP&P couit every two weeks and that they

will have to pay child support if they do not take this severally mentally disturbed child

back into their home.

DCP&P refused to help my client find a secure facility for this child. The child

would still be out on the street

as

a ticking time bomb if the prosecutor's office had not

sent an open minded investigator to interview the parents and the other children in the

house.

The police were contacted each time an event occurred. The police have

arrested the child for attempted murder.

The above parties were negligent. Their negligence caused emotional trauma

to

the entire family. The negligence allowed the child to commit additional crimes upon his

siblings.

The above parties did not do their duty under the law.

The aforesaid entities are vicariously liable for the acts of its servant's or

employees and in any other acts or omissions, which may

be

found during discovery.

he aforesaid individuals and entities engaged in careless and reckless conduct with

wanton disregard for the personal safety of my client's and their family. All of the victims

are still suffering the emotional trauma inflicted by Devon Hodges.

Damages in this matter are expected to be in excess of 5,000.00 in view of the

severe multiple injuries sustained by the claimants.

Please forward all correspondence

to

the undersigned and kindly note our

representation of this individual.

Very truly yours,

K E R N ~ AMPBELL BURNS

PJC

_ _ _ - ~

Linda

L

Campbell

LLC/tls

cc: James Harris, DAG

DCP&P Cape May Local Office