Bidlingmaier & Bidlingmaier, P.C.

Attorneys at Law
Clifford D. Bidlingmaier, III Phone: 267.364.5004 Pennsylvania Office
Member of PA and NJ Bars Fax: 267.364.5199 201 Corporate Drive East
[email protected] B idl in g ma ier La w. co m Langhorne, PA 19047

Keith J. Bidlingmaier New Jersey Office

Member of PA and NJ Bars 210 S. Broad Street, Suite B
[email protected] Trenton, NJ 08608

September 26, 2024

VIA CERTIFIED & REGULAR MAIL/RETURN RECEIPT REQUESTED

Clerk of the City of Trenton

CITY OF TRENTON
City Hall
319 East State Street
Trenton, New Jersey 08608

RE: ALEXIS DURLACHER vs. CITY OF TRENTON, et al.

Notice of Claim

Dear Sir or Madam:

Enclosed herewith please find the following documents in connection with the above-
referenced matter:

1. An original and one copy of a Notice of Claim Against a Public Entity pursuant to
N.J.S.A. 59:8-4; and

2. An original and one copy of a Notice of Claim for Damages against the City of
Trenton pursuant to N.J.S.A. 59:8-4.

Kindly file the aforementioned documents and return a filed copy of same to this office in
the envelope provided.

In the event that the enclosed Notice of Claim forms have not answered all of the questions
requested by each entity named therein, please identify what questions have not been answered on
the short form and additional long form, which we have completed in this matter.
Clerk of the City of Trenton
CITY OF TRENTON
September 26, 2024
Page Two

Thank you for your time and attention.

Very truly yours,

/s/ Clifford D. Bidlingmaier
CLIFFORD D. BIDLINGMAIER, III

CDB:km
Enclosures
cc: Department of Housing & Economic Development (w/enclosures) Certified & Regular
Mail/Return Receipt Requested)
Alexis Durlacher (w/enclosures) (Via Email Only)
 NOTICE OF CLAIM AGAINST A PUBLIC ENTITY
PURSUANT TO N.J.S.A. 59:8-4

A. The name and post office address of the Claimant:

Alexis Durlacher
c/o Bidlingmaier & Bidlingmaier, P.C.
210 South Broad Street, Suite B
Trenton, New Jersey 08608

B. Please send all notice to counsel:

Robin Kay Lord, Esquire

Law Offices of Robin Kay Lord, LLC
210 South Broad Street, Suite B
Trenton, New Jersey 08608

Clifford D. Bidlingmaier, III, Esquire

Bidlingmaier & Bidlingmaier, P.C.
210 South Broad Street, Suite B
Trenton, New Jersey 08608

C. Date, place and other circumstances of the occurrence or transaction

which gave rise to the claim asserted:

On or about July 30, 2024 at approximately 1:00 P.M., the Claimant, Alexis
Durlacher, a Lieutenant in the Trenton Police Department and practitioner
of the Jewish faith, arrived at City Hall to retrieve records relating to the
purchase of Columbus Kennel, a dog shelter. There, the Claimant spoke to
Arch Liston, the Director of Housing & Economic Development for the City
of Trenton, who referred to the Claimant and others who work with
Columbus Kennel as Nazis, and stated that all they do at the shelter is
euthanize dogs in a manner similar to the operation of a Nazi concentration
camp. Arch Liston has a patterned history of misconduct and inappropriate
behavior, and the Claimant has previously complained to other supervisors,
officers and employees of the City of Trenton without sufficient action
being taken. Josie Pabon and other supervisors, officers and employees of
the City of Trenton were present and/or aware and/or have information
regarding this incident and Arch Liston’s patterned history of misconduct
and inappropriate behavior.
 D. Description of Injuries:

The injuries sustained by Claimant include but are not limited to the mental
and physical suffering, emotional distress, and great pain associated
therewith which will result in a claim based in tort with attendant claims for
economic losses and for pain and suffering as permitted by law.

E. Name of Public Entity, employee or employees causing the injury,

damage or loss:

City of Trenton, Department of Housing and Economic Development, Arch

Liston and John Does (1-10).

F. Amount claimed as of date of presentation:

Economic losses and claims for pain and suffering are not yet calculable.

Dated: September 26, 2024 By: /s/ Robin Kay Lord

Robin Kay Lord, Esquire III, Esquire
On behalf of Claimant, Alexis Durlacher

Dated: September 26, 2024 By: /s/ Clifford D. Bidlingmaier

Clifford D. Bidlingmaier, III, Esquire
On behalf of Claimant, Alexis Durlacher
THIS CLAIM FORM MUST BE FILED WITHIN NINETY (90) DAYS OF THE ACCIDENT OR
OCCURRENCE OR YOU MAY FORFEIT YOUR RIGHT TO SUE (N.J.S. 59:8-1 ET SEQ. - SEE ALSO
RESOLUTION 96-_____)

File Number:

Forward to: Clerk of the City of Trenton

City Hall - Room 211
319 East State Street
Trenton, NJ 08608

CLAIM FOR DAMAGES AGAINST THE CITY OF TRENTON

(Use Additional Pages if Necessary)

1. Identification of claimants:

Name: Alexis Durlacher

Address: c/o Bidlingmaier & Bidlingmaier, P.C., 210 South Broad Street, Suite B, Trenton, New
Jersey 08608

Date of birth:

Social security number:

Home telephone: Work telephone:

2. If notice and correspondence in connection with this claim are to be sent to a person
other than the claimant, state that person's name, address and relationship to claimant:

Name: Clifford D. Bidlingmaier, III, Esquire, Bidlingmaier& Bidlingmaier, P.C.

Address: 210 South Broad Street, Suite B, Trenton, New Jersey 08608

Relationship to claimant: Counsel

3a. The occurrences of accident which gave rise to this claim.

Date and Time: July 30, 2024 at approximately 1:00 P.M.

b. Describe the location or place of the accident or occurrence

Location: Trenton City Hall, 319 East State Street, Trenton, New Jersey 08608
 c. Describe how the incident or occurrence happened.

On or about July 30, 2024 at approximately 1:00 P.M., the Claimant, Alexis Durlacher, a
Lieutenant in the Trenton Police Department and practitioner of the Jewish faith, arrived at
City Hall to retrieve records relating to the purchase of Columbus Kennel, a dog shelter.
There, the Claimant spoke to Arch Liston, the Director of Housing & Economic
Development for the City of Trenton, who referred to the Claimant and others who work
with Columbus Kennel as Nazis, and stated that all they do at the shelter is euthanize dogs
in a manner similar to the operation of a Nazi concentration camp. Arch Liston has a
patterned history of misconduct and inappropriate behavior, and the Claimant has
previously complained to other supervisors, officers and employees of the City of Trenton
without sufficient action being taken. Josie Pabon and other supervisors, officers and
employees of the City of Trenton were present and/or aware and/or have information
regarding this incident and Arch Liston’s patterned history of misconduct and inappropriate
behavior.

d. Draw diagram of the area of the incident. Label all intersecting street. Indicate “North” by
an arrow. Indicate house number where applicable. Mark “X” at exact spot of occurrence and stare
distance in feet from nearest intersecting streets if spot is not otherwise identifiable. Indicate public
property.

Trenton City Hall, 319 East State Street, Trenton, New Jersey 08608

e. State the name and address of the City Department, Division or Agency that you claim
caused your damage/injury.

City of Trenton and Department of Housing and Economic Development.

f. State the name of the City employees whom you claim were at fault, including any
information that will assist in identifying and locating them.

Arch Liston and John Does 1-10.

g. State the negligence or wrongful acts of the City Entity and city employees which caused
your damages. (Explain fully.)

See other Tort Claim Notice form attached hereto.

h. State the name and address of all witnesses to the accident or occurrence.

Unknown.
 i. State the names and address of all police officers and police departments who
investigated the accident.

Unknown

4a. Claim for Damages (check appropriate box):

( X ) Personal Injury ( ) Property Damage (X ) Other

If other, explain in detail: Claimant has suffered severe and permanent psychological injuries.

b. If you Claim Personal injury:

1) Describe your injuries resulting from this accident or occurrence.

See other Tort Claim Notice form attached hereto.

2) Do you claim permanent disability resulting from this accident or occurrence

X YES, NO Explain in detail the nature and extent of all injuries

claimed to be permanent disability.

See other Tort Claim Notice form attached hereto.

3) For each hospital, doctor, or other practitioner rendering treatment, examination

or diagnosis service, state:

Name of Hospital Address Date of Amt. of Amt. Paid or

Doctor or Other Treatment Charges Payable by
Facility to Date Other Sources
Such Insurance

To be supplied.
 5. If you claim lost wages or income as a result of this injury, state:

Name and address: To be supplied.

Position held and nature of work: To be supplied.

Average wages: To be supplied.

Dates lost: To be supplied.

Amount of wages lost: To be supplied.

NOTE: If you claim lost of income arises from self-employment, or sources other than wages, attach an
itemization showing the basis of your calculation of lost income.

6. Set forth any and all other losses claimed by you.

To be supplied.

7. If you claim property damage:

a. Describe the property damaged:

N/A

b. The present location and time when the property may be inspected.

N/A

c. Date property acquired.

N/A

d. Cost of property: $

N/A

Value of property at time of accident:

N/A

e. Description of damage:

N/A

f. Has the damage been repaired? If so, by whom, when and cost
of repairs:

N/A
 g. Attach each estimate of repair costs to this form.

N/A

h. Describe in detail the lost claimed by you for property lost or damaged.

N/A

i. Describe in detail all other items of lost and wages claimed by you and the
method by which you made the calculation.

To be supplied.

8. STATE THE TOTAL AMOUNT OF YOUR CLAIM as of the date of the presentation of
this claim. Include the estimated amount of any prospective injury, damage, or lost insofar as presently
known. Set forth the basis of computation of the amount claimed if not already set forth herein.

Economic losses and claims are not yet calculable.

9. Have you made a claim against anyone else (including insurance companies for any of
the losses or expenses claimed in this notice?

YES X NO

If yes, set forth the names and addresses of all persons and insurance companies against whom you
have made such claims.

10. Are any of the losses or expenses claimed herein covered by any policy if insurance?
(This question must be answered even if you do not intend to make a claim against such insurance
coverage.) YES __X NO

For each policy, state the name and address of the insurance company, policy umber and
benefits paid or payable.

11. If this claim involves an automobile please state.

1) The name of the Insurance Company covering the automobile:

N/A
 2) The name of your local agent:

N/A

3) Your policy number and dates of coverage:

N/A

12. 1) State the name of your Homeowner’s Insurance Company:

N/A

2) The name of your local insurance agent:

N/A

3) Your policy number:

N/A

13. If you have any other form or kind of indemnity, casualty, comprehensive or liability
insurance please state:

1. The name or names of the insurance company (ies) and policy number (s)

N/A

2. Type of coverage:

N/A

3. The name and address of your local insurance agent:

N/A

14. Have you received or agreed to receive any money from anyone for the damages
claimed herein? No If so, set forth the details of such agreement. (Including your
own insurance coverage together with medical and hospitalization coverage.)

15. The following items must be submitted with this notice:

1) Copies of itemized bills for each medical expense or other
losses and expenses claimed.

To be supplied.
 16. If any diagnostic tests were performed, state the type of test, name and address of place
where performed, date each test was performed and what each test disclosed. Attach a copy of the test
results.

To be supplied.

17. If treated by any health care provider, state the name and present address of each health
care provider, the dates and places where treatments were received and the date of last treatment.
Attach true copies of all written reports rendered to you by any such health care provider.

To be supplied.

18. If still being treated, the name and address of each doctor or health care provider
rendering treatment, where and how often treatment is received and the nature of the treatment.

To be supplied.

19. If a previous injury, disease, illness or condition is claimed to have been aggravated,
accelerated or exacerbated, specify in detail the nature of each and the name and present address of
each health care provider, if any, who ever provided treatment for the condition.

To be supplied.

20. If employed at the time of the accident, state: (a) name and address of employer; (b)
position held and nature of work performed; (c) average weekly wages for past year; (d) period of time
lost from employment, giving dates; and (e) amount of wages lost, if any.

Name and address: To be supplied.

Position held and nature of work: To be supplied.

Average wages: To be supplied.

Dates lost: To be supplied.

Amount of wages lost: To be supplied.

 21. If there has been a return to employment or occupation, state: (a) name and address of
present employer; (b) position held and nature of work performed; (c) present weekly wages, earnings,
income or profit.

Name and address: To be supplied.

Position held and nature of work: To be supplied.

Weekly wages: To be supplied.

22. If other loss of income, profit or earnings is claimed: (a) state total amount of the loss; (b)
give a complete detailed computation of the loss; and (c) state the nature and source of the loss of
income, profit and earnings, and the dates of the deprivation.

Total amount of loss: To be supplied.

Computation of loss: To be supplied.

Nature and source of loss: To be supplied.

23. Itemize in complete detail any and all moneys expended or expenses incurred for
hospitals, doctors, nurses, diagnostic tests or health care providers, X-rays, medicines, care and
appliances and state the name and address of each payee and the amount paid and owed each payee.

To be supplied.

24. Itemize any and all other losses or expenses incurred not otherwise set forth.

To be supplied.

25. State the names and address of all persons who have knowledge of any facts relating to the
case.

See answer to No. 3. By way of further answer, see other Tort Claim Notice form attached hereto.
 26. If you claim that the City of Trenton or any employee of the City of Trenton made any
admissions as to the subject matter of this lawsuit, state: (a) the date made; (b) the name of the person
by whom made; (c) the name and address of the person to whom made; (d) where made; (e) the name
and address of each person present at the time the admission was made; (f) the contents of the
admission; and (g) if in writing, attach a copy.

Date of admission: To be supplied.

Name of person making admission:

Name and address of person to whom made:

Name and addresses of witness to admission:

Contents of admission:

27. If you or your representative and the City of Trenton or any employee of the City have
had any oral communications concerning the subject matter of this lawsuit, state: (a) the date of the
communication; (b) the name and address of each participant; (c) the name and address of each person
present at the time of such communication; (d) where such communication took place; and (e) a summary
of what was said by each party participating in the communication.

Date of communication: To be supplied.

Participants:

Witnesses:

Place:

Summary:

28. If you have obtained a statement from any person not a party to this action, state: (a) the
name and present address of the person who gave the statement; (b) whether the statement was oral or
in writing and if in writing, attach a copy; (c) the date the statement was obtained; (d) if such statement
was oral, whether a recording was made and if so, the nature of the recording and the name and present
address of the person who has custody of it; (e) if the statement was written, whether it was signed by the
person making it; (f) the name and address of the person who obtained the statement; and (g) if the
statement was oral, a detailed summary of its contents.

Person who gave statement: To be supplied.

Oral or in writing:

Date of statement::

If oral, was it recorded?

If written, was it signed?

 Person who obtained statement:

Summary of statement:

29. If you claim that the violation of any statute, rule, regulation or ordinance is a factor in this
claim, state the exact title and section.

U.S. Civil Rights Act; New Jersey Civil Rights Act; New Jersey Constitution, U.S. Constitution, New
Jersey Statutes.

30. State the names and address of all experts consulted by you, including treating
physicians, state each such expert's area of expertise and attach a true copy of all written reports
provided to you. If a report is not written, supply a summary of any oral report provided to you.

To be supplied.

31. If this is an automobile accident case, do you have insurance coverage and/or PIP
benefits under an applicable policy or policies of automobile insurance? As to each such policy provide
the name and address of the insurance carrier, policy number, the named insured and attach a written
copy of the declaration sheet.

Name of insurance carrier: N/A

Address:

Policy number:

32. If you claim property damage, describe the property damaged, where that property is
located, the date the property was acquired and cost, a description of the damage, and attach copies of
any repair estimates or bills.

N/A
 33. State the total amount of your claim, including prospective injury, damage or loss insofar
as presently known.

See answer to No. 8.

34. If you claim property damage, are any of the losses covered by any policy of insurance?
If so, state the name and address of the insurance company, the policy number and any claim number.

Name of insurance carrier: N/A

Address:

Policy number:

35. If you claim personal injury, are any of your medical expenses covered by any policy of
insurance? If so, state the name and address of the insurance company, and the policy number.

Name of insurance carrier: See above.

Address:

Policy number:

36. Have you agreed to receive or received money or anything of value from anyone for the
damages claimed herein? If so, set forth the details of any such agreement.

No.

37. Have you ever filed any claim for damages or lawsuit for injuries against the City of
Trenton or any other party? If yes, give particulars.

No.

Dated: September 26, 2024 /s/ Clifford D. Bidlingmaier

Clifford D. Bidlingmaier, III, Esquire
Law Offices of Bidlingmaier & Bidlingmaier, P.C.
On behalf of Claimant