February 18, 2018 e-mail from John Paff to Pat McNamara of the Local Finance Board.
Dear Ms. McNamara:
Following this e-mail is my October 24, 2017 complaint against James Curtis Edwards and Jack Surrency. By letter of October 25, 2017, Mr. Cunningham dismissed my complaint because court case based on the same set of facts–Docket No. CUM-L-250-17–was then pending. Now that the court case has resolved (See Stipulation of Dismissal filed on January 12, 2018), I would like to re-file my complaint.
Please accept this new complaint for filing and acknowledge receipt within 30 days.
Very truly yours.
John Paff
Voice: 732-873-1251
Fax: 732-862-4449
e-mail: [email protected]
———- Forwarded message ———-
Date: October 24, 2017 (refiled February 9, 2018)
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 James Curtis Edwards and Jack Surrency who, at all times relevant to this complaint, served as members of the Bridgeton City Council (Cumberland County). In accordance with N.J.A.C. 5:35-1.1(b), following are the required elements of the complaint:
- State the point of the Local Government Ethics Law (LGEL) alleged to be violated.
N.J.S.A. 40A:9-22.5(d). “No local government officer or employee shall act in his official capacity in any matter where he, a member of his immediate family, or a business organization in which he has an interest, has a direct or indirect financial or personal involvement that might reasonably be expected to impair his objectivity or independence of judgment.”
- 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 James Curtis Edwards and Jack Surrency.
- Set forth in detail the pertinent facts surrounding the alleged violative action.
a. During a public meeting held on March 7, 2017, the Bridgeton City Council passed Resolution No. 43-17 (on-line here) that authorized the sale of several parcels of real estate to River Grove Urban Renewal Housing Partners, LLC for a housing project. The resolution noted that Tri-County Community Action Agency, Inc. was one of the “partners involved in the project.”
b. The resolution passed by a 3-2 vote, with Council President Gladys Luguardo-Hemple and members James Curtis Edwards and Jack Surrency voting in favor and members William D. Spence and Michael D. Zapolski, Sr. voting against. (The minutes are on-line here.)
c. Tri-County Community Action Agency, Inc. also goes by the name Gateway Community Action Partnership. Council member Edwards served on that organization’s board of directors at the time of his March 7th vote. These allegations are raised in paragraphs 9 and 11 in a citizen lawsuit and admitted to in the same paragraphs of the answer to the lawsuit. Edwards’ service on Gateway’s board is further confirmed by a March 10, 2017 letter written on Complete Care’s letterhead.
d. Surrency and Edwards serve, respectively, as Chairman of the Board and President/CEO of Complete Care Health Network. Screen shots of Surrency’s and Edward’s bios are here and here.
e. Complete Care is a self-described “partner” and “collaborator” with Gateway.” Complete Care’s website shows that Gateway is one of its “Partners & Collaborators.” Similarly, Gateway’s website features an article titled “Gateway, Inspira & Complete Care Partnership will WOW the community.“
f. At its April 18, 2017 regular meeting, the City Council brought up Resolution 67-17 which was very similar to Resolution 43-17. The resolution was passed 3-1, with Luguardo-Hemple, Edwards and Surrency voting in favor and Spence voting against. The minutes of the meeting are here.
Wherefore:
a. Edwards served on the Board of Directors of Gateway, which is a partner of the buyer of real property designated in a resolution that Edwards voted in favor of on March 7, 2017. That resolution was a “matter where [Edwards had] a direct or indirect financial or person involvement that might reasonable be expected to impair his objectivity or independence of judgment.”
b. Edwards served as the President/CEO of Complete Care, which is a partner or collaborator of Gateway which in turn is a partner of the buyer of real property designated in two resolutions that Edwards voted in favor of on March 7, 2017 and April 18, 2017. Those resolutions were “matter[s] where [Edwards had] a direct or indirect financial or person involvement that might reasonable be expected to impair his objectivity or independence of judgment.”
c. Surrency served as the Chairman of the Board of Complete Care, which is a partner or collaborator of Gateway which in turn is a partner of the buyer of real property designated in two resolutions that Surrency voted in favor of on March 7, 2017 and April 18, 2017. Those resolutions were “matter[s] where [Surrency had] a direct or indirect financial or person involvement that might reasonable be expected to impair his objectivity or independence of judgment.”
- 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.
- 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. Similar issues were raised in the matter of Martin v. Edward, et al, Cumberland County Docket No. CUM-L-250-17 but that matter is no longer pending.
Thank you for your attention to this matter. I ask that you please acknowledge your receipt of this complaint within 30 days.
Sincerely,
/s/ John Paff, Chairman
New Jersey Libertarian Party’s
Open Government Advocacy Project