VASQUEZ & BUONO FOR FREEHOLDER

VASQUEZ SUES ADDIEGO, FENTON, KENNEDY & OTHERS FOR DEFAMATION
In Their Most Expensive Campaign Ever, Burlco GOP Freeholder Candidates Resort to Maliciously Publishing False Statements

Today Democratic Candidate for Burlington County Freeholder Amy Vasquez filed suit for defamation of character after repeated vicious and deceptive personal attacks have been launched against her by the Burlco GOP.

“It is shameful that Dawn and Aubrey have resorted to such disgraceful campaign tactics. I am proud to have led a clean and honest campaign based solely on the issues,� Vasquez stated.

The complaint is reprinted below:

LAW OFFICES OF AMY E. VASQUEZ
BY: AMY E. VASQUEZ, ESQUIRE
205 East Union Street
Burlington, New Jersey 08016
(609)747-0509
Pro Se
____________________________________
:
AMY E. VASQUEZ, : SUPERIOR COURT OF NEW JERSEY
Plaintiff : LAW DIVISION
: BURLINGTON COUNTY
v. :
: DOCKET NO. L- -05
DAWN ADDIEGO, AUBREY FENTON, :
SEAN KENNEDY and JOHN DOES 1-10, : CIVIL ACTION
Defendants :
____________________________________

COMPLAINT AND DEMAND FOR JURY

Plaintiff Amy E. Vasquez (“Vasquez�), Pro Se, makes this Complaint against defendants Dawn Addiego, Aubrey Fenton, Sean Kennedy and John Does 1-10 by paragraphs as follows:

JURISDICTION

1. This Court has jurisdiction over the instant matter as the cause of action arose in the County of Burlington and one or more of the defendants are residents of the County of Burlington.

VENUE

2. Venue is proper pursuant to R. 4:3-2(a)(3) in that the cause of action arose in the County of Burlington.

PARTIES

3. Plaintiff Amy E. Vasquez is a resident of Burlington City, County of Burlington and a candidate for Burlington County Freeholder. Vasquez is also an attorney in private practice in New Jersey.

4. Defendant Dawn Addiego (“Addiego�) is a resident of Evesham Township, County of Burlington and a candidate for Burlington County Freeholder.

5. Defendant Aubrey Fenton (“Fenton�) is a resident of Willingboro Township, County of Burlington and a candidate for Burlington County Freeholder.

6. Defendant Sean Kennedy (“Kennedy�) is a resident of Medford Township, County of Burlington and the Executive Director of the Burlington County Republican Party.

7. John Does 1-10 are campaign consultants, television production companies and media advisors who are responsible for the production and distribution of television and print advertisements defaming plaintiff Vasquez.

COUNT ONE

8. In or about the summer and fall of 2005, in an effort to cause injury to Vasquez and her candidacy for Burlington County Freeholder, defendants Addiego, Fenton, Kennedy and John Does 1-10 embarked on a scheme to defame Vasquez in print and public broadcast media.

9. The defendants have caused to be published and distributed to general public direct mail advertisements, radio advertisements and television advertisements, which, among other things, are false and injurious to Vasquez’s reputation and good will in the community and are designed to cause others to avoid Vasquez.

10. In particular, the advertisements state:

(a) that Vasquez doesn’t pay her taxes

(b) that Vasquez was sued for failure to pay state income taxes

(c) that Vasquez had a warrant issued against her for failure to pay state taxes

and

(d) that Vasquez has never paid property taxes

11. The objective meaning of these statements to a reasonable person of ordinary intelligence is that Vasquez was criminally arrested or sought for criminal arrest by taxing authorities in New York for unpaid property taxes.

12. The defendants published these statements about Vasquez to the public while negligently, carelessly and recklessly failing to ascertain the falsity of the statements before communicating them.

13. The defendants also published these statements about Vasquez to the public while negligently, carelessly and recklessly failing to ascertain that the civil “warrant� was a clerical error and without factual support.

14. As a proximate result of the defendants’ defamatory statements, third parties have lowered their estimation of Vasquez and she has suffered pecuniary and non-pecuniary harm.

WHEREFORE, plaintiff Amy E. Vasquez demands judgment against the defendants for compensatory and punitive damages, together with interest, costs of suit, attorneys’ fees and any other relief that justice requires.

COUNT TWO

15. Plaintiff incorporates the above allegations of the Complaint as if set forth herein in their entirety.

16. The defendants published these statements about Vasquez to the public while knowing, or with reckless disregard for the truth, that the statements were false.

17. The defendants also published these statements about Vasquez to the public while knowing, or with reckless disregard for the truth, that the civil “warrant� was a clerical error and without factual support.

18. The defendants published these statements knowing, or with reckless disregard for their meaning, that the objective meaning of these statements to a reasonable person of ordinary intelligence is that Vasquez was criminally arrested or sought for criminal arrest by taxing authorities in New York for unpaid property taxes.

19. As a proximate result of the defendants’ defamatory statements, third parties have lowered their estimation of Vasquez and she has suffered pecuniary and non-pecuniary harm.

20. Defendants’ conduct is highlighted by similar activity intended to defame Vasquez’s running mate, Dean Buono, by conveying false statements that Buono is associated with organized crime. The pattern of defamatory activity by defendants evidences, at the very least, defendants’ reckless disregard for the truth.

WHEREFORE, plaintiff Amy E. Vasquez demands judgment against the defendants for compensatory and punitive damages, together with interest, costs of suit, attorneys’ fees and any other relief that justice requires.

DEMAND FOR TRIAL BY JURY

The plaintiff demands a trial by jury on all issues so triable.

CERTIFICATION

Pursuant to R. 4:5-1, this is to certify that, to the best of our knowledge, the matter in controversy herein is not subject to any other pending action in any other court or arbitration forum of which the undersigned is aware, nor is any other action or arbitration process contemplated.

DESIGNATION OF TRIAL COUNSEL

Pursuant to R. 4:25-4, Amy E. Vasquez, Esquire is designated as trial counsel on behalf of the plaintiff.
LAW OFFICES OF AMY E. VASQUEZ

BY: ____________________________
Amy E. Vasquez, Esquire

Pro Se

Dated: November 4, 2005

For more info, visit www.amyvasquez.com