Grab Your Popcorn! Update On The Michael Barisone & Lauren Kanarek Shooting

Dressage Hub Stands With Michael Barisone

When Lauren Kanarek was shot by Olympian Micheal Barisone, Dressage Hub did not hesitate to take a stand in supporting Michael. This sent the equestrian internet into a fit of rage until … the details started to be revealed. The New York Times went so far as to do an article claiming that Lauren Karenek was an innocent victim in this scenario.

Dressage Hub had already reported Lauren Kanarek to USEF under Safesport for bullying and harassment and nothing was done about it. Numerous people have come forward to Dressage Hub with their stories as well.

The Police Failed

The knowledge and information that we had at the time barely scratched the surface as to the extent of what Lauren Kanarek and Robert Goodwin are capable of. This week a civil suit was filed by Michael Barisone against the numerous police officers who failed to do anything because she does such a good job of playing the part of an innocent pretty blonde.

I have highlighted some of the key points to make this shorter for you to read. From stalking children, extensive drug use, cyberstalking and threats are all part of the story.

Grab your popcorn and get ready for a good read!

Court Filing

M01014
Christopher L. Deininger, Esq., N.J. Bar ID No. 004271996
DEININGER & ASSOCIATES, LLP
415 Route 10, Suite 1
Randolph, New Jersey 07869
(973) 879-1610; Fax (973) 361-1241
Attorneys for Plaintiff
MICHAEL L. BARISONE,
Plaintiff,
v.
WASHINGTON TOWNSHIP in Morris
County, New Jersey; POLICE OFFICER
BRIAN SZYMANSKI; POLICE
OFFICER DEREK HEYMER; POLICE
OFFICER BRIAN BIGHAM; POLICE
OFFICER MICHAEL HADE; POLICE
OFFICER PHILIP SEABECK; POLICE
OFFICER THOMAS FALLENI;
POLICE OFFICER ANDREW TESORI;
POLICE OFFICER JASON HENSLEY;
POLICE OFFICER MICHAEL
THOMPSON; POLICE OFFICER
ANTHONY COSTANTINO; POLICE
OFFICER ROGER GARRISON; JOHN
& JANE DOE 1-20, & ABC COMPANY
1-20,
Defendants.

SUPERIOR COURT
OF NEW JERSEY
LAW DIVISION – MORRIS
COUNTY
DOCKET NO.: MRS-L-______-21
COMPLAINT WITH JURY
DEMAND
Plaintiff MICHAEL L. BARISONE (“Plaintiff” and/or “BARISONE”), by and through his
attorneys DEININGER & ASSOCIATES, LLP, as and for his Complaint against the defendants,
makes the following allegations:
THE PARTIES & OTHER ACTORS

1. BARISONE is a 57-year-old Caucasian male who, at all times relevant hereto, had
   an established career as a top, Olympic trainer of horses and riders in the equestrian sport of
   dressage.
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2. At all times relevant hereto, BARISONE co-owned a farm located at 411 West
   Mill Road, Long Valley, New Jersey (the “Farm”), where BARISONE built and operated an
   Olympic-level, dressage horse farm and training facility, and thriving business.
3. At all times relevant hereto, the Farm had various visitors and/or occupants
   including but not limited to: (a) BARISONE and his partner Mary Haskins Gray (“Gray”),
   together with Gray’s minor children (the “children”); (b) Lauren S. Kanarek (“Kanarek”) and her
   boyfriend Robert G. Goodwin (“Goodwin”); © Ruth Cox (“Cox”); (d) Justin Hardin (“Hardin”),
   a long-term employee of BARISONE working and living at the Farm; and (e) numerous other
   persons who worked at the Farm, trained at the Farm, boarded horses at the Farm, and/or otherwise
   visited or occupied the premises.
4. Defendant WASHINGTON TOWNSHIP (“WASHINGTON TOWNSHIP”), is a
   municipality located in Morris County, New Jersey, where it operates, oversees, and/or manages
   various municipal services provided to its residents, including but not limited to public safety
   services provided by the Washington Township Police Department, located at 1 East Springtown
   Road, Long Valley, New Jersey 07853 (the “POLICE DEPARTMENT”); ambulance and
   associated medical services provided by a volunteer ambulance/EMT squad; and other services.
5. At all times relevant hereto, the following defendant-persons were members of the
   POLICE DEPARTMENT of WASHINGTON TOWNSHIP: (a) DEFENDANT POLICE
   OFFICER BRIAN SZYMANSKI (“SZYMANSKI”); (b) DEFENDANT POLICE OFFICER
   DEREK HEYMER (“HEYMER”); © DEFENDANT POLICE OFFICER BRIAN BIGHAM
   (“BIGHAM”); (d) DEFENDANT POLICE OFFICER MICHAEL HADE (“HADE”); (e)
   DEFENDANT POLICE OFFICER PHILIP SEABECK (“SEABECK”); (f) DEFENDANT
   POLICE OFFICER THOMAS FALLENI (“FALLENI”); (g) DEFENDANT POLICE OFFICER
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   ANDREW TESORI (“TESORI”); (h) DEFENDANT POLICE OFFICER JASON HENSLEY
   (“HENSLEY”); (i) DEFENDANT POLICE OFFICER MICHAEL THOMPSON
   (“THOMPSON”); (j) DEFENDANT POLICE OFFICER ANTHONY COSTANTINO
   (“COSTANTINO”); and (k) DEFENDANT POLICE OFFICER ROGER GARRISON
   (“GARRISON”). For purposes of this pleading, BARISONE may reference those persons
   collectively as the “POLICE OFFICER DEFENDANTS.”
6. Upon information and belief, at all times relevant hereto, each and every one of
   the POLICE OFFICER DEFENDANTS lived, resided, and/or worked in Morris County, New
   Jersey.
7. Now and at all times relevant hereto, fictitiously named defendants JOHN DOE &
   JANE DOE 1 through 20 are persons presently unknown who, individually, and/or in concert with
   the other defendants and/or other actors named here, and/or acting under the direction and control
   of one or more of the other defendants or actors named here, committed acts and omissions
   connected with injury and resulting damages caused to BARISONE.
8. Now and at all times relevant hereto, fictitiously named other defendants ABC
   COMPANY 1 through 20 corporations, partnerships, limited liability companies, and/or other
   types of entities, presently unknown which, individually, and/or in concert with the other
   defendants and/or actors named here, and/or acting under the direction and control of one or more
   of the other defendants or actors named here, committed acts and omissions connected with injury
   and resulting damages caused to BARISONE.
   ALLEGATIONS & CLAIMS
9. Commencing in or about the late 1990s, BARISONE became co-owner of the
   Farm and started transforming the property into a world-class training facility for dressage.
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10. Himself a one time, highly competitive dressage rider who had grown up in
    Upstate New York where he started riding at an early age, BARISONE had gravitated towards
    training riders and horses in dressage, investing years of time, training and effort to become one
    of the sport’s leading trainers.
11. BARISONE’s career reached a milestone when, at the 2016 Olympics held in
    Brazil, multiple competitors trained and/or coach by BARISONE won medals in the competitions.
    BARISONE operated a thriving business through which he trained riders and/or horses, raised
    horses, and/or boarded horse.
12. People interested in excelling in the sport of dressage sought out BARISONE to
    become their trainer, boarding their horses at the Farm (including certain horses valued in excess
    of $500,000), and coming there to train with BARISONE and his business in his world-class
    dressage barn with an adjoining club room, office, locker room, and other facilities.
13. The Farm included as well a farm house, which was a single-family residence
    divided into two living spaces under one roof with shared spaces and facilities, such as hallways,
    entrances, porches, and the like.
14. While the farm house could be characterized as having two living spaces, the fact
    was that the farm house constituted a single domicile, with its residents living like a single
    household.
15. The physical layout of the Farm included frontage on West Mill Road, with the
    farm house about 400 feet back from the road, and the dressage barn and training facility another
    1,600-1,700 feet up an unlit driveway behind the farm house.
16. Commencing in or about March 2018, Kanarek sought to become a pupil of
    BARISONE for purposes of training in dressage.
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17. With her parents’ financial support, Kanarek wanted to train with BARISONE and
    board her horse at the Farm during the summer season which covers (essentially) the months of
    April through September, following which (during the winter season) Kanarek would return to
    the Carolinas where she lived with her boyfriend Goodwin and boarded her horse(s).
18. Kanarek’s aspirational goal, upon information and belief, was to “train for the
    Olympics” and become a “world class” dressage rider, though the reality seemed more likely to
    be that Kanarek would remain an amateur who enjoyed the sport and the personal satisfaction one
    has when they take lessons and improve in a pursuit they love.
19. At that time Kanarek presented as an attractive, blond woman in her mid- to late
    30’s, with acceptable horseback riding skills, an acceptable horse, and what appeared to be nearly
    limitless financial support and backing of her father, a wealthy attorney from Livingston, New
    Jersey.
20. But there was an exceptionally dark and disturbing reality concerning Kanarek that
    was being hidden from view by Kanarek and her parents.
21. Unbeknownst the BARISONE, Kanarek had a history of domestic conflict
    following which she was banished from residing with her family.
22. Unbeknownst to BARISONE, Kanarek was a former heroin addict with a lengthy
    criminal history, including criminal assault.
23. Unbeknownst to BARISONE, Kanarek’s background included criminal
    harassment and stalking, including harassment that involved extensive use of the Internet and/or
    social media to make veiled and direct threats of injury, mayhem, violence, and criminal acts
    against persons with whom she was having interpersonal conflict.
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24. Unbeknownst to BARISONE, Kanarek’s tactics in the past included making false
    reports and false statements against people she perceived to be her “enemy,” to child-protectiveservices agencies and/or other governmental agencies, including the police.
25. Unbeknownst to BARISONE, Kanarek’s past included owning firearms and at
    least one incident of discharging her firearm, out of anger and rage, at other people and/or their
    personal property.
26. Unbeknownst the BARISONE, Safesport, the organization which purports to
    protect people from abuse and harassment within the pursuit of sports, had multiple complaints
    about Kanarek from persons Kanarek had harassed, stalked, and/or otherwise endeavored to
    “destroy.”
27. Unbeknownst the BARISONE, Kanarek’s boyfriend Goodwin had an equally
    disturbing past which included but was not limited to: drug addiction and heroin abuse; violence;
    criminal conduct; stalking; harassment; and the like.
28. But for BARISONE’s lack of knowledge of Kanarek’s hidden background,
    BARISONE would not have agreed to become her dressage trainer; would not have agreed to
    permit Kanarek’s horse(s) to board at the Farm; and/or would not have engaged in any other form
    of relationship with Kanarek as coach, trainer, house guest, or otherwise.
29. Similarly, but for BARISONE’s lack of knowledge of Goodwin’s hidden
    background, BARISONE would not have agreed to permit Kanarek to bring Goodwin to the Farm
    as her boyfriend and/or in any other capacity Kanarek and Goodwin might have proffered.
30. BARISONE himself has a medical history which includes psychological trauma
    from abuse as a child.
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31. At all times relevant hereto, BARISONE had been in treatment and/or counseling
    for his past trauma and status as a victim of child abuse and resulting trauma.
32. In that regard, BARISONE was an “egg shell” victim of future trauma who was
    vulnerable and susceptible to sustaining injury from harassment, stalking, verbal assault, and
    threats of violence from persons like Kanarek and/or Goodwin.
33. At all times relevant hereto, BARISONE displayed the traits, characteristics and
    affect of a person having psychological vulnerability and potential victimization from abuse, in
    need of protection from the police under circumstances indicating a basis for being in fear of
    injury, harm, violence, and/or threats of same.
34. Commencing in or about May 2019, Kanarek and Goodwin became temporary
    house guests of BARISONE in the farm house at the Farm.
35. BARISONE had told Kanarek that she could not become a tenant at the Farm due
    to water damage to the farm house which made it unlivable.
36. Upon being informed of that circumstance, Kanarek’s father commenced
    threatening BARISONE with abusive legal process and litigation, for purposes of forcing
    BARISONE to permit Kanarek to live at the Farm, even temporarily as BARISONE’s house
    guest.
37. Upon information and belief, Kanarek’s father did everything in his power to
    ensure that Kanarek and Goodwin would reside at the Farm (even temporarily) because Kanarek
    was banned from residing with her father and/or other immediate family in New Jersey due to
    Kanarek’s past history of violence, abuse, assault, drug use, psychotic behavior, and the like.
38. Separate and apart from that temporary “house guest” arrangement, Kanarek was
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    again boarding her horse in the barn at the Farm.
39. Soon after she started stay as a house guest at the Farm, Kanarek commenced
    displaying behavior towards BARISONE and/or Gray which was increasingly threatening and/or
    otherwise unacceptable.
40. Kanarek’s behavior included an upward spiral of harassment and stalking of
    BARISONE, Gray, and/or Gray’s children, both on the Internet and throughout social media like
    Facebook, where Kanarek made veiled and direct threats against them of ever-increasing severity.
41. As the situation escalated, BARISONE commenced uncovering the highly
    problematic and threatening criminal and social backgrounds of Kanarek and Goodwin.
42. It was in or about June 2019, for example, that BARISONE learned of Kanarek’s
    status as a drug addict, criminal, and person with a history of harassment, stalking, threats of
    violence, and violent assault, against others.
43. BARISONE and Gray began to observe, find, and/or otherwise become aware of
    Internet postings by Kanarek, in which Kanarek threatened harm, injury and/or violence against
    BARISONE, Gray, Gray’s minor children living at the Farm, and/or horses boarding in the barn.
44. As of July 31, 2019, and at all relevant times thereafter, BARISONE’s affect,
    statements and behaviors evidenced, outwardly, that BARISONE was being psychologically
    assaulted and victimized by Kanarek and Goodwin, such that the defendants knew, intentionally
    disregarded and/or recklessly disregarded, BARISONE’s mounting psychological distress and
    potential psychiatric breakdown that could occur unless appropriate and sufficient action was
    taken by the defendants to intervene.
    The July 31, 2019 Incident
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45. The situation continued to escalate, out of control, with Kanarek increasing her
    terroristic threats, harassment, stalking, and/or other criminal behaviors until the night of July 31,
    2019, when BARISONE made his first “911” call to the WASHINGTON TOWNSHIP POLICE
    DEPARTMENT seeking emergency assistance.
46. On July 31, 2019, at approximately 20:00 hours, BARISONE called “911” and
    reported that he had been assaulted verbally by Kanarek and/or Goodwin; that he and others at
    the Farm were being subjected to other criminal behaviors by Kanarek and/or Goodwin, including
    but not limited to behaviors which constituted unlawful criminal threats, harassment, cyber
    stalking, and cyber harassment; their fear; and other relevant information.
47. Thereafter, DEFENDANT TESORI and DEFENDANT SEABECK arrived at the
    Farm, whereupon BARISONE and/or others repeated their reports to WASHINGTON
    TOWNSHIP that there had been a verbal assault by Kanarek and/or Goodwin; that BARISONE
    and others at the Farm were being subjected to other criminal behaviors by Kanarek and/or
    Goodwin including but not limited to behaviors which constituted unlawful criminal threats,
    harassment, cyber stalking, and cyber harassment; and that BARISONE and others were in fear
    of immediate danger and injury to their physical health, wellbeing and/or the wellbeing of their
    property.
48. DEFENDANT TESORI and DEFENDANT SEABECK intentionally disregarded
    the facts and circumstances being reported to them and intentionally failed to act to protect
    BARISONE and/or the others making the report to WASHINGTON TOWNSHIP against
    Kanarek and Goodwin.
49. For example, during the July 31, 2019 incident, BARISONE’s affect, statements
    and behaviors evidencing, outwardly, that BARISONE was being psychologically assaulted and
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    victimized by Kanarek and Goodwin, such that the police knew, intentionally disregarded and/or
    recklessly disregarded, BARISONE’s mounting psychological distress and potential psychiatric
    breakdown that could occur unless appropriate and sufficient action was taken by the defendants
    to intervene in the developing criminal dispute.
50. Thereafter, DEFENDANT TESORI and DEFENDANT SEABECK intentionally
    authored and issued a Washington Twp Police Department Investigation Report that was
    materially false and misleading (the “August 1, 2019 Police Report”).
51. The August 1, 2019 Police Report was materially false and misleading in that the
    report, inter alia: (a) failed to document the complaint by BARISONE and the others that some of
    them were in fear of immediate danger and injury to their physical health, wellbeing and/or the
    wellbeing of their property; and/or (b) failed to document other facts and circumstances necessary
    to accurately and effectively convey the true circumstances and resulting material threat of injury,
    harm, and/or other mayhem occurring at the Farm that day.
    The August 1, 2019 Incident
52. The situation continued to escalate, out of control, with Kanarek increasing her
    terroristic threats, harassment, stalking, and/or other criminal behaviors, causing BARISONE to
    make his second “911” call to the WASHINGTON TOWNSHIP POLICE DEPARTMENT
    seeking emergency assistance.
53. On August 1, 2019, at approximately 18:00 hours, BARISONE called “911” and
    again reported that he had been assaulted verbally by Kanarek and/or Goodwin; that he and others
    at the Farm were being subjected to other criminal behaviors by Kanarek and/or Goodwin,
    including but not limited to behaviors which constituted unlawful criminal threats, harassment,
    cyber stalking, and cyber harassment; their fear; and other relevant information.
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54. Thereafter, DEFENDANT HENSLEY and DEFENDANT SEABECK arrived at
    the Farm and, upon information and belief, in abject violation of standard police protocol, policy
    and procedure, interviewed Kanarek and Goodwin before the DEFENDANT POLICE
    OFFICERS interviewed BARISONE, the criminal complainant who called “911.”
55. When DEFENDANT HENSLEY and DEFENDANT SEABECK finally did
    interview BARISONE and/or the others being threatened by Kanarek and/or Goodwin,
    BARISONE and/or others reported to WASHINGTON TOWNSHIP that there had been a verbal
    assault by Kanarek and/or Goodwin; that BARISONE and others at the Farm were being subjected
    to other criminal behaviors by Kanarek and/or Goodwin including but not limited to behaviors
    which constituted unlawful criminal threats, harassment, cyber stalking, and cyber harassment;
    and that BARISONE and others were in fear for their lives and in fear of immediate danger and
    injury to their physical health and wellbeing, and/or to the wellbeing of their property.
56. DEFENDANT HENSLEY and DEFENDANT SEABECK intentionally
    disregarded the facts and circumstances being reported to them and intentionally failed to take
    appropriate action choosing instead to avoid their duty to act by falsely characterizing the situation
    as a “private dispute,” a tactic those defendants, the other defendants, and particularly defendant
    WASHINGTON TOWNSHIP, utilized unlawfully as a practice, custom, and/or unofficial policy.
57. For example, during the August 1, 2019 incident, BARISONE’s affect,
    statements, and behaviors evidencing, outwardly, that BARISONE was being psychologically
    assaulted and victimized by Kanarek and Goodwin, such that the police knew, intentionally
    disregarded, and/or recklessly disregarded BARISONE’s mounting psychological distress and
    likely psychiatric breakdown that was going to occur unless appropriate and sufficient action was
    taken by the defendants to intervene in what was obviously a police matter and not a “private
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    dispute.”
58. Thereafter, DEFENDANT HENSLEY and DEFENDANT SEABECK
    intentionally authored and issued a Washington Twp Police Department Investigation Report that
    was materially false and misleading (the “August 2, 2019 Police Report”).
59. The August 2, 2019 Police Report was materially false and misleading in that the
    report, inter alia: (a) failed to document the complaints by BARISONE and the others that they
    were in fear for their lives and/or in fear of immediate danger and injury to their physical health
    and wellbeing, and/or to the wellbeing of their property; and/or (b) failed to document other facts
    and circumstances necessary to accurately and effectively convey the true circumstances and
    resulting material threat of injury, harm, and/or other mayhem occurring at the Farm that day.
60. In connection with their responds to BARISONE’s August 1, 2019 “911” call and
    their visit to the Farm, DEFENDANT SEABECK contacted a Morris County Assistant Prosecutor
    for purposes of discussing the August 1, 2019 incident with the Morris County Prosecutor’s Office
    (“MCPO”).
61. During that call with MCPO, DEFENDANT SEABECK failed intentionally to
    make a truthful and/or accurate report of the August 1, 2019 incident at the Farm, which
    inaccuracies included, but were not limited to, the failure of WASHINGTON TOWNSHIP to
    report that BARISONE and others had expressed that they were in fear for their lives and/or in
    fear of immediate danger and injury to their physical health and wellbeing, and/or to the wellbeing
    of their property, from harm threatened by Kanarek and/or Goodwin.
62. Upon information and belief, the intentional inaccurate reporting of the August 1,
    2019 incident was part of a practice, custom and policy adopted by WASHINGTON TOWNSHIP
    to endeavor to limit police involvement by falsely characterizing as “civil matters” and/or “private
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    disputes” incidents which, in fact, were criminal in nature.
63. There are other residents of WASHINGTON TOWNSHIP who have been
    subjected to the same illegal and unlawful treatment by WASHINGTON TOWNSHIP and its
    POLICE DEPARTMENT.
    The August 3, 2019 Incident
64. The situation continued to escalate, out of control, with Kanarek increasing her
    terroristic threats, harassment, stalking, and/or other criminal behaviors, causing BARISONE to
    make his third “911” call to the WASHINGTON TOWNSHIP POLICE DEPARTMENT seeking
    emergency assistance.
65. On August 3, 2019, at approximately 9:00 hours, BARISONE called “911” and
    again reported that he and others at the Farm were being assaulted verbally by Kanarek and/or
    Goodwin; that he and others at the Farm were being subjected to other criminal behaviors by
    Kanarek and/or Goodwin, including but not limited to behaviors which constituted unlawful
    criminal threats, harassment, cyber stalking, and cyber harassment; their fear; and other relevant
    information.
66. Thereafter, DEFENDANT THOMPSON and DEFENDANT FALLENI arrived at
    the Farm and, upon information and belief, in abject violation of standard police protocol, policy
    and procedure, interviewed Kanarek and Goodwin before the DEFENDANT POLICE
    OFFICERS interviewed BARISONE, the criminal complainant who called “911.”
67. When DEFENDANT THOMPSON and DEFENDANT FALLENI finally did
    interview BARISONE and/or the others being threatened by Kanarek and/or Goodwin,
    BARISONE and/or others reported to WASHINGTON TOWNSHIP that there had been a verbal
    assault by Kanarek and/or Goodwin; that BARISONE and others at the Farm were being subjected
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    to other criminal behaviors by Kanarek and/or Goodwin including but not limited to behaviors
    which constituted unlawful criminal threats, harassment, cyber stalking, and cyber harassment;
    and that BARISONE and others were in fear for their lives and in fear of immediate danger and
    injury to their physical health and wellbeing, and/or to the wellbeing of their property.
68. For example, BARISONE and/or the other victims reported expressly to the
    responding POLICE OFFICER DEFENDANTS a number of material, salient facts which they
    chose intentionally to disregard, including the following:
    (a) Kanarek was believed to have possession of, and/or current access to, a loaded
    firearm;
    (b) Kanarek had a history of threatening to discharge and/or actually discharging her
    loaded firearm at people and property for the purpose of causing harm, injury
    and/or damage;
    © Kanarek threatened BARSIONE and others that Kanarek was coming to attack
    them with “weapons hot,” meaning that she was armed and ready to discharge a
    firearm at one or more of them;
    (d) Kanarek was making threats of harm, physical harm, violence, and/or mayhem
    against BARISONE, Gray, and/or others, in writing, on the Internet through
    social media posting which were and/or could be made available for the
    DEFENDANT POLICE OFFICERS to see; and/or,
    (e) Kanarek had a criminal history, history as a drug addict, and other personal
    history demonstrating that Kanarek was a clear, immediate, and present danger
    to BARISONE, Gray, Gray’s children, others at the Farm, and/or horses being
    boarded at the Farm.
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69. During the August 3, 2019 Incident, Kanarek and/or Goodwin expressly told the
    responding DEFENDANT POLICE OFFICERS that Kanarek/Goodwin had place electronic
    devices on the premises, permitting Kanarek and Goodwin to intercept and thereafter disclose
    private oral communications BARISONE, Gray, and/or others were having at the Farm
    (hereinafter, the “Eavesdropping”).
70. The placement of those devices without consent of the property owner, upon
    information and belief, is criminal trespassing under New Jersey law.
71. The Eavesdropping was unlawful under New Jersey law.
72. Moreover, the disclosure of unlawfully intercepted oral communications is a crime
    under New Jersey law.
73. Nevertheless, the responding DEFENDANT POLICE OFFICERS failed to
    investigate the criminal acts Goodwin has reported to them he had been committing, failed to take
    other appropriate non-discretionary action in response to notification that such criminal conduct
    was occurring, and intentionally failed to intervene.
74. DEFENDANT THOMPSON and DEFENDANT FALLENI intentionally
    disregarded all of those facts and circumstances being reported to them and intentionally failed to
    act to intervene in what obviously was a police matter and not just a “private dispute.”
75. Those POLICE OFFICER DEFENDANTS also disregarded, during the August 3,
    2019 incident, BARISONE’s affect, statements, and behaviors evidencing, outwardly, that
    BARISONE was being psychologically assaulted and victimized by Kanarek and Goodwin, such
    that the police knew, intentionally disregarded, and/or recklessly disregarded BARISONE’s
    mounting psychological distress and likely psychiatric breakdown about to occur unless
    appropriate and sufficient action was taken by the defendants to intervene.
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76. Thereafter, DEFENDANT THOMPSON and DEFENDANT FALLENI
    intentionally authored and issued a Washington Twp Police Department Investigation Report that
    was materially false and misleading (the “August 8, 2019 Police Report”).
77. The August 8, 2019 Police Report was materially false and misleading in that the
    report, inter alia: (a) failed to document the complaint by BARISONE and the others that some of
    them were in fear for their lives and in fear of immediate danger and injury to their physical health
    and wellbeing, and/or the wellbeing of their property; (b) failed to document the facts and
    circumstances concerning Kanarek’s actual or potential possession of a firearm, and her threats
    to use the firearm against BARISONE and others by coming for them with “weapons hot”; and/or
    © failed to document other facts and circumstances necessary to accurately and effectively
    convey the true circumstances and resulting material threat of injury, harm, and/or other mayhem
    occurring at the Farm that day.
78. In connection with their responds to BARISONE’s August 3, 2019 “911” call and
    their visit to the Farm, the responding DEFENDANT POLICE OFFICERS failed to contact the
    MCPO and/or any of its assistant prosecutors for purposes of discussing the August 3, 2019
    incident and/or reporting to the MCPO the escalating, increasingly dangerous situation at the
    Farm.
79. Upon information and belief, the intentional inaccurate reporting of the August 3,
    2019 incident was another example of the practice, custom and policy adopted by
    WASHINGTON TOWNSHIP to endeavor to limit police involvement by falsely characterizing
    as “civil matters” and/or “private disputes” incidents which, in fact, were criminal in nature.
80. Upon information and belief, had the defendants (especially the responding
    DEFENDANT POLICE OFFICERS) acted appropriately in response to BARISONE’s criminal
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    complaint and “911” emergency call on August 3, 2019, the defendants would have discovered
    that in the early morning hours on or about August 3, 2019, Goodwin was conducting Internet
    searches in an effort to find address information for the location where Gray’s children were about
    to be attending a family reunion; that Goodwin and Kanarek were stalking Gray’s children for
    criminal, deviant and illegal purposes; and that there was probable cause to intervene in the
    situation which was not a private dispute but, rather, a criminal matter.
    The August 4, 2019 Incident
81. The situation continued to escalate, out of control, with Kanarek increasing her
    terroristic threats, harassment, stalking, and/or other criminal behaviors, causing BARISONE to
    make his fourth “911” call to the WASHINGTON TOWNSHIP POLICE DEPARTMENT
    seeking emergency assistance.