In an effort to promote transparency for the public, all documents relating to the case of Jance Hosbach, David P. Morrisette and Sandra S. Morrisette (Plaintiffs) v. Town of Phillipsburg Townd Council (Defendent) will be posted. This is related to challenging Ordinance 2021-14. This ordinance changed the zoning of the Peron Howard Street Property from residental to heavy industrial. We, the plaintiffs, firmly believe that the Court will vacate Ordinance 2021-14 because of conflicts of interest and the zoning for the Peron Howard Street property will be returned to residential.
You will be able to find links to these documents on this page. Just click on the text of the document you would like to download.
One quick note is that Brenda and Garis Kormandy removed themselves as plaintiffs last summer. They are not currently part of the lawsuit.
Click on the text to download the document or file.
| 08-10-2022-FollowupLetterToOralArgumentsAttorneyDickson | This is a follow up letter to Judge Shanahan providing specific dates and times of dates of trials and dates of activities regarding Ordinance 2021-14, the ordinance that changed the land along the riverfront of the Delaware River to industrial and allowed for Peron Construction to go forward with plans for a warehouse. |
| 07-29-2022-CourtNoticeForOralArgumentsAug102022 | Notification of oral arguments at a pre-trial conference scheduled for August 10, 2022 |
| 07-28-2022-ClerkNotice-RescheduledFor08102022 | A notice from the Court Clerk for a date and time for oral arguments before the court. The date will be August 10, 2022 at 11 AM. This is a copy of the email sent to the attorneys. |
| 07-28-2022-AdjournmentRequestByDickson | A request from Attorney Peter Dickson to reschedule the August 3rd court date due to a conflict. |
| 07-27-2022-CourtNoticeSubmittedByCaseManagement | Notice from court of time and date for oral arguments on August 3, 2022. |
| 07-26-2022-NotificationOfOralArgumentsOnAug032022 | Court notice for oral arguments to be heard by the court on August 3, 2022. This is essentially the email sent to the attorneys notifying them of the date and time of oral arguments. |
| 07-18-2022-NotificationForCaseManagementFor07252022 | Notification for a July 25, 2022 case management conference. A meeting for the attorneys and the court. This document is basically a copy of the email that was received notifying the attorneys of the case management conference. |
| 07-12-2022-CaseManagement-ConferenceScheduledForJuly252022 | Notification for a July 25, 2022 case management conference. A meeting for the attorneys and the court. |
| 07-11-2022-ResponseFromDickson-06-48-pm | This is one of two response letters written in response to the letter from the Monech law firm. This response is written by Attorney Peter Dickson. Although there is some similarity between the two responses, I recommend reading both responses written by Attorney Peter Dickson. |
| 07-11-2022-ResponseFromDickson-2-14-pm | This is one of two response letters written in response to the letter from the Monech law firm. This response is written by Attorney Peter Dickson. Although there is some similarity between the two responses, I recommend reading both responses written by Attorney Peter Dickso |
| 07-08-2022-LetterFromMonech | This letter tries to make the argument that Michael Perrucci was not an active partner of the law firm when the vote on the warehouse was taken, so therefore there can't be a conflict of interest. In the end, I believe the letter actually supports our case. |
| 05-26-2022-BriefSubmittedByDickson_PeterForThePlaintiffs | This brief is a response by Hosbach, Morrisette and Morrisette to the brief the Town of Phillipsburg filed on 05-13-2022. |
| 05-13-2022-BriefSubmittedByTownOfPhillipsburg | This is a response from the Town of Phillipsburg in response to the brief filed by Hosbach, Morrisette and Morrisette against the Town of Phillipsburg on 04-13-2022 |
| 04-13-2022-Plaintif-Brief-CivilCaseJacket.pdf | BRIEF submitted by DICKSON, PETER, D of POTTER & DICKSON on behalf of JANICE HOSBACH, GARIS KORMANDY, BRENDA KORMANDY, SANDRA S MORRISETTE, DAVID P MORRISETTE against TOWNOFPHILLIPSBURGTOWNCOUNCIL |
| 03-16-2022-Interrogatory-Responses-Final-w-exhibits | This is a response, from the Town of Phillipsburg, to questions that were asked by the plaintiffs' attorney. This was not downloaded from the eCourts system, but since this was publicly entered into evidence, this is able to be posted with the list of court documents on this site. |
| 03-08-2022-ConsentOrder-CivilCaseJacket.pdf | Consent Order - GRANTED by Judge SHANAHAN, KEVIN, M |
| 03-02-2022-Correspondence-From-Atty-Potter.pdf | GENERAL CORRESPONDENCE submitted by DICKSON, PETER, D of POTTER & DICKSON on behalf of JANICE HOSBACH, GARIS KORMANDY, BRENDA KORMANDY, SANDRA S MORRISETTE, DAVID P MORRISETTE against TOWNOFPHILLIPSBURGTOWNCOUNCIL |
| 03-02-2022-FiveDayOrder-CivilCaseJacket.pdf | A note from Attorney Monech stating that the Town of Phillipsburg shall provide responses to the interogetories by March 14, 2022. The plaintifs shall file a trial brief by March 14, 2022. The plaintiffs may limit their initial brief to issues of conflict of interest, without prejudice, and may address other issues in later proceedings. Defendents shall file a trial brief by May 13, 2022. |
| 02-23-2022-CourtNotice-CivilCaseJacket.pdf | Dated February 22, 2022 - eCourts sends a notice there will be a Case Managenet Conference on February 28, 2022. |
| 02-22-2022-Clerk-Notice-Notification.pdf | eCourt sends a notice that the Case Management Conference scheduled for February 23, 2022 has been rescheduled for February 28, 2022 |
| 02-15-2022-ClerkNotice-Notification.pdf | eCourt sends a notice of a Case Management Conference for February 23, 2022 |
| 02-10-2021-CourtNotice-CivilCaseJacket.pdf | Warren County Superior Court schedules a Case Magement Conference for February 23, 2022 |
| 02-01-2022-GeneralCorrespondence-CivilCaseJacket.pdf | Ordinance 2021-27 was vetoed and the town went dark on returning interogetores that were due the first week of December 2021, but the town did not wish to proceed on until it passed Ordinance 2021-27. Ordinance 2021-27 did not survive a veto and the town continued not to provide a response to the interogatories. Attorney Peter Dickson correctly states that Ordinance 2021-14 is still in play. Attorney Peter Dickson requests a Case Management Conference. |
| 12-06-2021-OppositionToMotion-CivilCaseJacket.pdf | Letter from my (David Morrisette) attorney Peter Dickson opposing postponing discovery. Just because they removed one conflicted member of the Council from the voting, we would like answers regarding other members of Council. The town promised to have answers to the discovery at the 11/17/2021 Case Management Conference. It is believed that there were more than one conflicted Council Member that voted on the original ordinance Ordinance 2021-14. |
| 12-06-2021-ClerkNotice-Notification.pdf | Notice sent from eCourt that there is a case management conference scheduled for 12/14/21 |
| 12-01-2021-GeneralCorrespondence-CivilCaseJacket.pdf | Letter from Attorney Moench, attorney for the defendents, asking the court to hold off on the case regarding Ordinance 2021-14. The town is trying to pass a similar ordinance without the vote of Frank McVey, which they claim will moot the case against Ordinance 2021-14. With the effort to pass Ordinance 2021-17 without Frank McVey, it kind of seems that the Town of Phillipsburg believed there is a strong case that Frank McVey had conflict of interest. Ordinance 2021-27 was vetoed and there was not vote to override the veto, hence Ordinance 2021-14 remained teh ordinance in effect. |
| 11-18-2021-CourtNotice-CivilCaseJacket.pdf | Case Management Conference scheduled for 12/14/21 - sent by Warren Superion Court |
| 11-08-2021-CourtNoticeByCaseManagement.pdf | Notice sent by ecourts of Case Management Conference for 11/17/21 |
| 09-16-2021-CourtNoticeByCaseManagement-CivilCaseJacket.pdf | Dated 09/07/21 Court notice of Case Management Converence scheduled for 09/12/21 |
| 09-07-2021-Notification.pdf | Clerks notice of Case Management Conference scheduled for 9/13/21 |
| 08-26-2021-AnswerFromTownOfPhillipsburg-CivilCaseJacket.pdf |
Town responds to compaint and answers very few questons Answer In Lieu Of Prerogative Writs |
| 08-03-2021-Notification.pdf | Scheduling of Case Management Conference |
| 07-29-2021-AffidavitOfService.pdf | Vicoria Leiner, Municipal Clerk, Served |
| 06-26-2021-CivilCaseJacket-TrackAssignment.pdf | Track Assignment Noticee |
| 06-25-2021-CivilCaseJacket.pdf | Complaint In Lieu Of Prerogative Writs |