PashmanStein
December 10, 2015
VIA HAND DELIVERY
Clerk, Superior Court of New Jersey
Union County Courthouse
2 Broad Street
Elizabeth, New Jersey 07207
Re: Harry Scheeler v. Union County and Joanne Rajoppi, in her capacity as Records
Custodian for Union County
UNN-L-3070-15,
Our File No. 9871-022
Dear Sir/Madam:
On behalf of Plaintiff, Harry Scheeler, | enclose herewith an original and one copy of the
following documents in the above-mentioned matter:
Plaintiff’s Notice of Motion for Recusal
Letter brief in support of Recusal
Proposed Order
Certification of Samuel J. Samaro; and
Certification of Service;
yeep
Please return a filed copy of each document to us in the enclosed self-addressed, stamped
envelope.
SAMUEL 3. SAMARO. |
ce: Hon. Robert Kirsch, 4.5.C. (w/enclosures, Via Hand Delivery)
Brian P. Trelease, Esq. (w/enclosures, via Hand Delivery)
Pashan ste PC
21 Main Steet ste 200
ackensac 6760
Prone 201485200
Fe2014885556
‘ ashmanstin comPASHMAN STEIN
A Professional Corporation
Court Plaza South
21 Main Street, Suite 200
Hackensack, NJ 07601
(201) 488-8200
CJ GRIFFIN (#031422009)
‘Attorneys for Plaintiff,
Harry Scheeler
HARRY SCHEELER, : SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: UNION COUNTY
Plaintiff,
Docket No.: UNN-3070-15
v.
UNION COUNTY and JOANNE RAJOPPI, in Civil Action
her capacity as Records Custodian for Union
County,
CERTIFICATION OF SERVICE
Defendants.
I certify that on December 10, 2015 an original and one copy of Notice of Motion for
Recusal, letter brief in support thereof, Proposed Order, and Certification of Samuel J. Samaro
were sent via hand delivery to the Clerk, Superior Court of New Jersey, 2 Broad Street,
Elizabeth, New Jersey 07207.
A courtesy copy of the aforementioned documents were also sent via hand delivery to
Hon. Robert Kirsch, J.8.C. Brian P. Trelease, Esq.
Superior Court of New Jersey Office of the County Counsel
Union County Courthouse 10 Elizabethtown Plaza
2 Broad Street, Elizabeth Elizabeth, New Jersey 07207
New Jersey 07207I certify that the foregoing statements made by me are true. I am aware that if any of the
foregoing statements made by me are willfully false, I am subject to punishment.
PASHMAN STEIN
A Professional Corporation
ieys for Rlaintff,
Harry Schecler
Date: December 10, 2015
SAMUEL J. SAMARO
Terry J. Walker V County of Gloucester, Salem County Correctional Facility Warden Raymond Skradzinski, Former Salem County Corrections Officer Elbert B. Johnson II