Update: The resolution of this complaint is on-line here.
September 30, 2014

Patricia Parkin McNamara
Local Finance Board
101 S Broad St – PO Box 803
Trenton, NJ 08625-0803
(via e-mail only to [email protected])

Dear Ms. McNamara:

We intend this e-mail to be our complaint against Douglas Long who, at all times relevant to the activities alleged below, served both as Deputy Director of the Cumberland County Board of Chosen Freeholders and also as partner in the law firm of Long, Marmero and Associates, LLP.  This complaint is also against Jacqueline Jennings who, at all times relevant to this complaint, served as Mayor of Willingboro Township in Burlington County and who had been awarded a position as the Division Head of the Office of Purchasing in Cumberland County.

In accordance with N.J.A.C. 5:35-1.1(b), following are the required elements of the complaint:

1. State the point of the Local Government Ethics Law (LGEL) alleged to be violated. 

N.J.S.A. 40A:9-22.5(a), (c) and (d).

2. State the name(s) and title(s) of the parties involved in the action and against whom the complaint is filed. 

Complainants John Paff and the New Jersey Libertarian Party and Respondents Douglas Long and Jacqueline Jennings.

3. Set forth in detail the pertinent facts surrounding the alleged violative action. 

Attached are three documents:

1. Willingboro’s January 1, 2013 Reorganization Meeting Minutes.
2. Cumberland County Resolution 2013-43 passed on January 8, 2013.
3. Cumberland County Resolution 2013-78 passed on January 22, 2013.

These documents show that:

1. Jacqueline Jennings was Willingboro’s mayor in 2013.
2. Jacqueline Jennings was appointed to head Cumberland County’s Office of Purchasing on January 8, 2013 for a term to begin on February 1, 2013.
3. Jacqueline Jennings’ appointment as head of Office of Purchasing was rescinded on January 22, 2013.  The stated reason for rescinding the resolution is because Jacqueline Jennings had secured a different position.
4. Douglas Long moved and seconded both the resolution that established and the one that rescinded Jacqueline Jennings’ appointment.
5. At the time of Jacqueline Jennings’ appointment, Douglas Long’s law firm served as Willingboro Township’s Labor Counsel.

More information and background on, see the citizen’s questions and comments along with the Freeholders’ responses starting at 00:14:48 on the video on-line here.

We contend that it violated the LGEL for Freeholder Douglas Long, approximately a week after his law firm had been awarded Willingboro’s Labor Counsel contract, to hire Willingboro’s mayor as a Division Head for Cumberland County.  We likewise contend that it violated the LGEL for Jacqueline Jennings to have participated in a meeting where a contract was given to Douglas Long’s law firm when she was, on information and belief, engaged in negotiating for a position with the County for which one of the law firm’s partners served as Freeholder.  We believe that the rescission of Jennings’ appointment prior to it taking effect is of no moment because the LGEL also prohibits”attempts” by officials to use their positions for unwarranted gains.  See, e.g. N.J.S.A. 40A:9-22.5(c).

This appears to be a situation where both Long and Jennings at least attempted to use their positions to reward each other with taxpayers’ money.  We believe that this is the type of conduct that the LGEL was intended to prohibit.  Yet, given the Board’s dismissals in LFB-11-147 and LFB-11-149 (Harper) (compared to its decision to levy a $500 fine in LFB-12-012 (Costa)), we are not able to discern any workable standard used by the Board in adjudicating of LGEL cases.  Accordingly, when we perceive a possible violation, as we do here, we bring it in the form of a complaint in hopes that the Board, when issuing its decision, will help clarify the LGEL’s contours and establish some predictability of its future determinations.

4. Indicate whether the complaint concerns the complainant in any way and what, if any, relationship the complainant has to the subject of the complaint. 

Complainants have no interest in or relationship to this complaint greater than any other citizen or organization who wishes for all government officers and employees to comply fully with the Local Government Ethics Law.

5. Indicate any other action previously taken in an attempt to resolve the issue and indicate whether the issue is the subject of pending litigation elsewhere. 

No other action has been taken previously in an attempt to resolve this issue and this issue is not the subject of any pending litigation. Thank you for your attention to this matter. I ask that you please acknowledge your receipt of this complaint within 30 days.


/s/ John Paff, Chairman
New Jersey Libertarian Party’s
Open Government Advocacy Project
P.O. Box 5424
Somerset, NJ 08875
Voice: 732-873-1251

Chairman of the New Jersey Libertarian Party's Open Government Advocacy Project. Please send all comments to [email protected]