PAUL C.

WILLIAMS
35 BROAD STREET #C4
TOMS RIVER NJ 08753-6564
p.c.williams70@gmail.com
732.998.6707
Plaintiff, Pro Se

IN THE UNITED STATES DISTRICT COURT

DISTRICT COURT OF NEW JERSEY - TRENTON

PAUL C. WILLIAMS, Civil Action No. 3:18-cv-13092-BRM-TJB

Plaintiff, CIVIL ACTION

vs. PLAINTIFF’S FIRST SET OF

INTERROGATORIES
RICHARD BOSLEY, et al.,
(BOSLEY)
Defendants.

TO: Richard Bosley

c/o Barry A. Stieber, Esq.
Gilmore & Monahan, P.C.
Ten Allen Street
PO Box 1540
Toms River NJ 08753

PLEASE TAKE NOTICE that Plaintiff, Paul C. Williams

(“WILLIAMS”), hereby demands that Defendant, Richard Bosley
(“BOSLEY”) provide answers to the following interrogatories
under oath or certification within the time prescribed by Local
Rules.

PLEASE TAKE FURTHER NOTICE that, in responding to these

interrogatories, Defendant is to follow the Instructions set
forth herein.

DATED: July 26, 2019

Paul C. Williams
Plaintiff, Pro Se

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 INSTRUCTIONS

A. The answers to these Interrogatories shall be based upon

information known or reasonably available to you. These
Interrogatories are continuing. If, at any time after service
of answers and prior to trial, you or your representatives
(including counsel) obtain additional responsive information or
discover that information given in your answers is erroneous,
you shall promptly submit supplemental or amended answers. Such
supplemental or amended answers may be filed from time to time,
but not later than (15) days after such information is received.

B. Each Interrogatory is to be answered separately and as

completely as possible. The fact that investigation is
continuing or that discovery is not complete shall not be used
as an excuse for failure to answer each Interrogatory as fully
as possible. The omission of any name, fact or other item of
information from the answers shall be deemed a representation
that such name, fact or item was not known to you, your counsel
or other representatives at the time of service of the answers.

C. In answering these Interrogatories, furnish all

information, however obtained and including hearsay, which is
available to you or known by or in possession of you, your
agents or attorneys, or appearing in your records.

D. With respect to your answer to each Interrogatory,

identify each document relied on or forming the basis for the
answers given and/or corroborating or in any way relating to the
answer to the Interrogatory. You are to retain in your
possession all documents reviewed or referred to in preparing
responses to these Interrogatories, all documents to be
identified in response to these Interrogatories and all other
documents, if any, that pertain to, relate to or are in any way
connected with the claims asserted in this matter.

E. When an Interrogatory or part thereof inquires into a

particular paragraph or portion of the Complaint, identify each
document claimed to corroborate or in any way relate to the
allegations of said paragraph or subparagraph of the Complaint.

F. If you do not have all information necessary to prepare

a complete response to any Interrogatory, provide all
information you do have and state (1) that your information is
incomplete; (2) why your information is incomplete; (3) what
additional efforts you will take (or has initiated) to provide
more complete responses; (4) when you believe such information

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shall be forthcoming; and (5) your supplemental response when
you obtains more information.

G. The person(s) answering these Interrogatories shall

designate which information is not within their personal
knowledge and, as to that information, shall state the name and
address of every person from whom it was received or, if the
source of the information is documentary, a full description of
such document(s), including the location thereof, or in lieu of
such description, attach a copy of the document(s) which is
(are) the source of the information provided. You are requested
to produce documents as they are kept in the usual course of
business and to organize and label them so that they correspond
to the numbered Interrogatory(s) and, where applicable, the
subparts of the Interrogatory(s), to which the documents are
responsive.

H. If you claims a privilege not to answer any discovery

request, identify the type of privilege, the basis for the claim
of privilege, the communication, document or other information
for which a claim of privilege is claimed, the author,
addressee, recipients and date of a document if a privilege is
claimed relative to a document, and a description of the subject
matter of the information sought or the responsive document. If
you claim as privilege with regard to partial information
requested in an Interrogatory or with respect to a portion of a
responsive document, answer the Interrogatory to the extent that
it requests non-privileged information and produce the portion
of the document for which you do not claim a privilege. Any
document produced in part should be clearly marked so that it
will be evident that the copy produced is dissimilar from the
original. Pursuant to the Federal Rules of Civil Procedure, in
connection with any claim of privilege, you must provide such
additional information as may be required to enable the Court to
adjudicate the propriety of your claim of privilege.

YOU ARE HEREBY SPECIFICALLY INSTRUCTED NOT TO DESTROY, DISCARD,

ALTER OR OTHERWISE REMOVE FROM ACCESSIBILITY ANY DOCUMENT (AS
DEFINED ON THE FOLLOWING PAGES) RELATED IN ANY WAY TO THE
ALLEGATIONS IN YOUR COMPLAINT, DEFENDANTS’ ACTUAL OR POTENTIAL
DEFENSES TO SUCH ALLEGATIONS AND/OR RESPONSIVE TO ANY DEFENDANT
INTERROGATORY OR DOCUMENT REQUEST UNTIL SUCH TIME AS THIS ACTION
IS DISMISSED WITH PREJUDICE OR OTHERWISE CONCLUDED.

DEFINITIONS

The following definitions shall apply throughout these

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Interrogatories:

A. “You” and “your” shall mean the Defendant, Richard Bosley,

listed above and any person(s) or entities acting on his behalf,
including counsel.

B. “Plaintiff” shall mean Plaintiff, Paul C. Williams, listed

above and any person(s) or entities acting on his behalf,
including counsel.

C. “Defendants” shall mean any or all of the defendants named in

the present action, or any specified individual defendant.

D. “Complaint” and “Action” shall mean the Complaint filed by

Plaintiff in this matter.

E. The words “document” or “documents” mean any written, typed,

printed, other graphic material, tape, film, or other recorded
matter, however recorded, transcribed, punched, taped, filed or
reproduced and whether on paper, cards, tapes, film, electronic
facsimile, computer storage device, computer hard drive, or any
other media, including, but not limited to, books and records,
memoranda, handwritten or other notes, minutes, photographs,
correspondence, telegrams, telex, telefax, e-mail, diaries,
messages, memo pads, booklets, interoffice or intra-office
communications, transcripts, tapes or other recordings,
pamphlets, log books, letters, confirmations, reports, printed
matter and publication press releases, summaries, tabulations,
cancelled or uncancelled checks or drafts, reports, studies,
charts, graphs, agreements, contracts, amendments or addenda to
agreements or contracts, purchase orders, account reports,
payment records, reports or opinions of consultants or counsel,
accountants’ or auditors’ reports or opinions, bookkeeping
entries, financial statements, tax returns, investigations,
periodicals, appointment calendars, work papers, annual and
quarterly reports, policy releases or statements, and any other
records and documentary materials of any nature. This definition
encompasses not only originals but also any and all copies which
are different in any way from the original whether by
interlineation, receipt stamp, notation, indication of copies
sent or received or otherwise, or having attached thereto any
alterations, notes, comments or other material not appearing on
the original or any other copy, which shall also include drafts,
revisions of drafts and other preliminary material, from
whatever source, underlying, supporting or used in the
preparation of any other document.

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F. The term “communication” shall include, without limitation,
any letter, correspondence, telegram, telex, TWX, telefacsimile,
fax, e-mail, notice, message, memorandum or other written
communication or transcription or notes of a communication, as
well as any verbal conversation or other statement from one
person to another, including, but not limited to, any interview,
conference, meeting or telephone conversation.

G. The terms “refer(s) to,” “referring to,” “relate(s) to” or

“relating to” shall include, without limitation, constitute,
comprise, concern, record, discuss, mention, note, reflect,
evidence, memorialize, analyze, describe, comment upon, refer
to, or have any connection with or have any tendency to prove or
disprove the matters set forth.

H. “Interrogatory” or “Interrogatories” means the

Interrogatories directed to any Defendant by Plaintiff in this
matter.

I. The use of the male gender is meant to include the female and
neuter genders and vice-versa.

J. The words “person” and “persons” mean all individuals and

entities, including, without limitation, sole proprietorships,
associations, companies, partnerships, joint ventures,
corporations, unincorporated organizations, joint-stock
companies, trusts, governments or political subdivisions thereof
and governmental agencies.

K. The terms “identify” and “identity” have the following

meanings:

1. When used in reference to a natural person, it means to

state his or her full name; last known residence and business
addresses and telephone numbers; length of service with the
last known employer; present title and job description as well
as each title and job description during the past ten years;

2. When used in reference to a corporation, it means to state

the full name of the corporation, the date and state (or
country, if not domestic) of its incorporation and the address
and telephone number of its principal place of business, the
states or countries in which it has qualified to do business,
and the date of its qualifications in each state or country,
and to identify its officers and directors;

3. With respect to a person other than a natural person,

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corporation, or partnership, it means to state its proper name
or designation, its principal office address and telephone
number, and to identify its managers, officers, directors and
agents;

4. When used in reference to a document, it means to state the

type of document (e.g., letter, telegram, magnetic tape, chart,
etc.), describing it sufficiently for purposes of a request to
produce or subpoena duces tecum; to state its substance; to
identify its author and its originator; to identify the person,
if any, who provided it to the Plaintiff; to state the means by
which Plaintiff acquired knowledge of its contents or obtained
access to it; to state when and how Plaintiff first became aware
of it; to state its date or dates; to identify all of its
addresses; to identify all of its recipients; to state its
present location and identify its custodian. If Plaintiff
produces such document, state this fact and identify only so
much of it as cannot be identified from a review of the
document.

5. When used in reference to a communication, it means:

(i) if such communication was oral, to identify the person

speaking and the person spoken to, to state the date and place
of communication; to state its substance; and to identify
those persons who were present during the communications; and

(ii) if such communication was contained in a document, to

identify the document;

6. When used in reference to tangible things, including, but not

limited to, products or other physical objects, it means to
furnish a complete description of the thing, including its
common designation, its physical characteristics and any other
designated characteristics, and some specific reference
sufficient to segregate the thing from other things of similar
description;

7. When used in reference to the report of an expert, it means

to state the date the report was submitted; to identify the
person to whom the report (and each copy of the report) was
submitted; to identify each person who has reviewed the report;
and to identify each person having present custody of a copy of
the report.

L. As used herein, the term “state whether” means:

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 1. To provide a “yes” or “no” response to the inquiry.

2. In the event Plaintiff is unable to respond to the inquiry

by “yes” or “no”, set forth the reason or reasons Plaintiff
cannot so respond and otherwise respond fully and accurately
in accordance with the information Plaintiff has available.

M. The terms “describe,” “describing” and “set forth” mean to

state the substance of the event, circumstance, communication,
representation, conversation, meeting, transaction, occasion or
other occurrence in question; the date, time, place and identity
of all persons present thereat or participating therein; that
which each such person said and did; the approximate duration of
such occurrence; the method or means of communication employed;
the identity of all documents relating thereto; and the identity
of all persons having knowledge of such occurrence; as well as
the date and means when and whereby such knowledge was first
acquired.

N. As used herein, the term “state in detail each and every fact
upon which Plaintiff relies and will rely to prove this
allegation (or contention or understanding) ...” or similar
clause to that effect means to set forth each and every fact,
item of information, inference, conclusion, argument or other
thing which Plaintiff contends supports, or tends to indicate
the truth of, the contention, answer or allegation which is the
subject matter of the inquiry and as to such fact, etc., set
forth the identity of each and every source thereof and/or other
basis for asserting its truth or existence, including the date
on which Plaintiff first received such information.

O. “Each” shall include “every” and “every” shall include

“each.”

P. “And” shall include “or” and “or” shall include “and.”

Q. “Any” shall include “all” and “all” shall include “any.”

R. “Date” shall mean the exact day, month and year, if

ascertainable, or, if not ascertainable, the best approximation,
including relationship to other events as a means of
approximating the date.

S. “Williams” shall mean Plaintiff, Paul C. Williams, listed

above and any person(s) or entities acting on his behalf,
including counsel.

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 INTERROGATORIES

INTERROGATORY 1 Provide your full name, present address, and

date of birth.

ANSWER:

INTERROGATORY 2 Identify and describe the dates and title of

all instruction and training you have received as a part of your
employment with the Jackson Township Police Department.

ANSWER:

INTERROGATORY 3 In connection with any suspension, warning,

disciplinary procedure, or reprimand by any supervisors you have
been subject to, state the details and, with regard to each that
there are, specifically include:

a. the nature;
b. date;
c. outcomes of any such disciplinary action;
d. by whom such action was initiated and/or carried out; and
e. attach any records, reports, or other writings pertaining
thereto.

ANSWER:

INTERROGATORY 4 In connection with any membership you have

or have had to any labor union(s) relating to your employment as
a law enforcement officer, describe your membership and
specifically include the name of such union, how long you have
been a member, the date when you became a member and whether
there is written policies and practices pertaining to such
membership.

ANSWER:

INTERROGATORY 5 Do you believe that you would be subject to

any form of retaliation by members of the Jackson Township
Police Department and Local 168 of the Policemen’s Benevolent
Association for providing information about another member of
the Jackson Township Police Department and Local 168 of the
Policemen’s Benevolent Association that could jeopardize a
members employment, or its conditions, and/or subject a member
to criminal prosecution.

ANSWER:

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INTERROGATORY 6 Are you considered “working” during the time
you take to review, consider, and answer these interrogatories
and, thus, are being paid your salary as a member of the Jackson
Township Police Department.

ANSWER:

INTERROGATORY 7 State whether you are a member of any labor

union relating to your employment as a law enforcement officer
and, if so, please elaborate on the name of such union, how long
you have been a member, the date when you became a member and
whether there is written policies and practices pertaining to
such membership.

ANSWER:

INTERROGATORY 8 Identify any other litigation or legal

proceedings in which you have been involved as a party for
conduct you were alleged to have committed in your capacity as a
law enforcement officer, by stating the name of the parties
involved in the case, the docket number, the name of the court
or agency, and the nature of the litigation or legal proceeding,
the outcome of that litigation or legal proceeding.

ANSWER:

INTERROGATORY 9 If the answer to the preceding interrogatory

is affirmative and there was a judgment entered against you, or
the matter was settled, where the party that brought the matter
was compensated financially, including attorney fees, state
whether such compensation was paid by you, the Patrolmen's
Benevolent Association or similar labor union that represents
law enforcement officers, and/or liability insurance through the
agency that employed you at the time the cause of action arose.

ANSWER:

INTERROGATORY 10 If the answer to the preceding interrogatory

is affirmative, state whether you were represented by counsel
and, if so, whether such counsel was paid for by you, the
Patrolmen's Benevolent Association or similar labor union that
represents law enforcement officers, and/or liability insurance
through the agency that employed you at the time the cause of
action arose.

ANSWER:

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INTERROGATORY 11 State whether you prepared a document
captioned “incident report,” dated June 27, 2018 and with regard
to Case No. 18-49530, and therein state:

On 06/27/2018 this officer responded to the area of S. Hope Chapel Road for a six
car fatal motor vehicle crash. The final rest place of the crash was located in front of
64 S. Hope Chapel Road. The roadway was shutdown between E. Veterans Hwy
and Linda Drive. There were several emergency vehicles with activated emergency
lights located on both sides of the closure.

During the course of the investigation, specifically when the Ocean County
Criminalistic Unit (CIU) was processing the scene, this officer along with P.O.
Chesney #195, and Sgt. Crowley #182 encountered the defendant later identified as
Paul Williams. Mr. Williams was observed walking up to the crash scene on the
property of 64 S. Hope Chapel Road with a camera and appeared to be taking
pictures of the scene
 and the deceased’s body. At that time Mr. Williams was
advised that he could not take pictures and needed to leave the area. Mr. Williams
replied don’t start with me. When asked who he was he replied don’t focus on me
worry about your scene. Again he was asked not to take pictures and to leave the
scene. He replied it is his first amendment right and that he was on private property.
While speaking with Mr. Williams, P.O. Chesney was able to contact the owner of 64
S. Hope Chapel Road, John Dziedzic who had exited his residence. Mr. Dziedzic
advised, MR. Williams did not have permission to be on his property and he did not
want him to stay there. Mr. Williams was advised he needed to leave the crash
scene and he could take all the pictures he wanted from a point approximately 100
yards north of the crash scene. Myself and P.O. Chesney began to escort Mr.
Williams away from the scene. When it appeared that Mr. Williams was going to
comply, P.O. Chesney returned to the scene.

As I continued to escort Mr. Williams away from the scene, he turned back towards
me as to walk back in a direction closer to the scene. At this time I put my left arm up
in an extended fashion placing my hand in the chest area of Mr. Williams. He
immediately in an aggressive fashion swung his hand at me striking my left arm and
stating to the effect, don’t put your fucking hands on me. This officer grabbed Mr.
Williams and guided him to the ground. While on the ground Mr. Williams was flailing
his arms and legs as to get away from my control. Sgt. Crowley, Sgt. Kucowski, and
P.O. Travisano all came over to assist this officer. Mr. Williams was placed in
handcuffs without further incident.

While Mr. Williams was being escorted to one of the patrol vehicles, he fell to the
ground and stated his knee gave out. Dispatch was advised to have first aid respond
to the scene. Mr. Williams was transported to Community Medical Center by Quality
First Aid. P.O. Falzarano accompanied them to the hospital.

A Use of Force Report was completed by all officers involved and sent to the
county.
 Mr. Williams was later transported to the Jackson Township Police

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 Department and processed.

He was charged with : 2C:12-1B(5)A on W2018-000331 and 2C:29-2A(1) and

2C:29-1A on $2018-000330.

This officer seized his Nikon D7100 digital camera and Iphone pending a possible
search warrant. Both items were secured in an evidence locker at the Jackson
Township Police Department.

If the answer to this interrogatory is affirmative, please

elaborate with regard to the portion wherein you state:

a. “Williams was observed walking up to the crash scene on the

property of 64 S. Hope Chapel Road * * * “ and, more
specifically, what you mean by “up to the crash scene.”

b. “Williams was advised that he could not take pictures and

needed to leave the area” and, more specifically, the name of
every person who so “advised” Williams and, if including you,
by what authority did you do so.

c. “Williams replied don’t start with me” and, more

specifically, describe Williams’ tone and demeanor.

d. Williams was “asked who he was” and, more specifically, the

name of every person who so “asked” and, if including you,
what was the point of that question and would it have made any
difference in his being advised that he could not take
pictures and needed to leave the area.

e. Williams “replied don’t focus on me worry about your scene”

and, more specifically, describe Williams’ tone and demeanor.

f. “[a]gain he was asked not to take pictures and to leave the

scene” and, more specifically, the name of every person who so
“asked” and, if you, by what authority did you do so.

g. “[a]gain he was asked not to take pictures and to leave the

scene” and, more specifically, whether Williams was actually
in the scene.

h. Williams “replied it is his first amendment right that he

was on private property” and, more specifically, whether you
gave any consideration to Williams’ alleged statement and, if

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so, what did you consider, what did you conclude, and what did
you proceed to do thereafter. As well and if you did not give
any consideration to Williams’ alleged statement, please
elaborate with regard to why you did not and what did you
proceed to do thereafter.

i. Mr. Dziedzic advised that, in addition to Williams not

having permission to be on the property, Mr. Dziedzic “did not
want him to stay there” and, more specifically, whether you
personally heard Mr. Dziedzic say that.

j. Mr. Dziedzic advised that, in addition to Williams not

having permission to be on the property, Mr. Dziedzic “did not
want him to stay there” and, more specifically, whether it
would surprise you to learn that there were several additional
people who prepared reports in connection with the same
incident and, although all referenced Mr. Dziedzic advising
that Williams did not have permission to be on the property,
none included any reference to Mr. Dziedzic stating, as you
did, that “he did not want him to stay there.”

k. Williams “was advised he needed to leave the crash scene

and he could take all the pictures he wanted from a point
approximately 100 yards north of the crash scene” and, more
specifically, with regard to

a) who so advised Williams,

b) whether Williams was actually in the crash scene from
which he was advised that he needed to leave, and
c) who established that a football field length away from
the crash scene, as opposed to where he was before you
confronted him and escalated into confronting Mr. Dziedzic,
was were Williams or any other civilian or member of the
Media/Press could take all he wanted.

l. yourself and [Kevin] Chesney began to escort Mr. Williams

away from the scene” and, more specifically, whether you used
any physical contact to compel Williams’ compliance. As well,
please also elaborate with regard to what authority did you
rely on to “escort” Williams “away from the scene” and, if
there was any physical contact, what authority did you rely on
to touch Williams.

m. “[w]hen is appeared that Mr. Williams was going to comply,

[Kevin] Chesney returned to the scene” and, more specifically,
with regard to whether you mean that Williams was not
complying at some point while you and Kevin Chesney were

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“escorting” him “away from the scene” and, if so, what did you
or anyone else do, if anything, to “escort” Williams “away
from the scene” during the time when he did not appear to be
complying.

n. as you “continued to escort Williams away from the scene,

he turned back towards me as to walk back in a direction
closer to the scene” and, more specifically, what law would
you say, if any, Williams had violated by turning back toward
you “as to walk back in a direction closer to the scene.”

o. you put your “left arm up in an extended fashion placing my

hand in the chest area of Mr. Williams” and, more
specifically,

a) were you ever so gentle and kind when you placed your
hand on Williams’ chest area, as someone might perceive
from the words of a romance novel, or did you use force and
push and otherwise shove Williams backward in the course of
placing your hand in his chest area, and
b) by what authority did you rely on to put your hand in
the chest area of Williams.

p. Williams, “in an aggressive fashion swung his hand at me

striking my left arm and stating to the effect, don’t put your
fucking hands on me” and, more specifically, with regard to
whether Williams struck you in your throat, groin, shin,
chest, eye, facial or head areas, or anywhere else and, , what
injury, if any, did you sustain. As well, please also
elaborate further with regard to whether you believed that, in
allegedly striking your arm and stating “don’t put your
fucking hands on me,” it was Williams’ conscious object to
cause you bodily injury and, if so, describe the facts, if
any, upon which you rely as the basis for that belief.

q. you “grabbed Mr. Williams and guided him to the ground”

and, more specifically, with regard to whether you mean that
you were able to single-handedly and simply guide Williams to
the ground or that you lacked the skill and physical ability
to do so and required the assistance of at least four of your
colleagues to get Williams onto the ground.

r. “While on the ground Mr. Williams was flailing his arms and
legs as to get away from my control” and, more specifically,
with regard to whether you would be willing to, and are
capable of, reenacting what you described as Williams
“flailing his arms and legs” so as to get away from control

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 while on the ground.

s. “Mr. Williams’ personal property was turned over to his

girlfriend, J. Adelizzi at his request” and, more
specifically, who turned over the personal property and, if
not by you, how do you know the property was turned over, to
whom it was turned over, and do you know what the personal
property consist of.

t. you seized Williams’ camera and iphone pending a possible

search warrant and, more specifically, with regard to whether
you knew of facts that led you to reasonably believe that
those items were used in furtherance of the commission of a
crime, contain evidence of a crime, and/or were otherwise
subject to search and, if so, what those facts were.

ANSWER:

INTERROGATORY 12 On October 31, 2018, did you provide

testimony wherein you answered, under oath, a series of
questions that were being posed to you by Danny Ljungberg and
that, in particular, consisted of the following:

Q Turning your attention to June 27, 2018, were you working that day?

A Yes, I was.

Q And specifically were you investigating a fatal motor vehicle crash in the area of
[64] South Hope Chapel Road?”

A Yes.

Q And during that investigation Paul Williams entered the crash scene and began
to take pictures of the scene and the deceased?

A That’s correct.

Q Mr. Williams was advised not to take any further pictures and to leave the area?

A Correct.

Q To which he relied: Don’t start, just worry about your scene.

A Correct.

Q He was asked again to leave, at which time he replied: It’s my First Amendment
right to be here and I’m on private property.

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A Correct.

Q At that time officers made contact with the owner of the property; correct?

A Yes

Q And he advised that Mr. Williams did not have his permission to be there?

A Yes.

Q You were escorting Mr. Williams away from the scene; correct?

A Yes.

Q And at that time he tried again to reenter the area?

A Yes.

Q You put your left hand on Mr. Williams’ chest in an attempt to keep him from
reentering?

A Correct.

Q At which point he struck your left arm and said: Don’t put your fucking hands on
me.

A Correct.

Q And when he struck your left arm, it caused a stinging sensation in your arm;
correct?

A Correct.

Q Mr. Williams was guided to the ground and as you were attempting to place him
under arrest, he was struggling with you?

A Yes.

If the answer to this interrogatory is affirmative, please

elaborate with regard to certain portions of that testimony.
More specifically and where you answered:

a. “Yes” to the question of “were you investigating a fatal

motor vehicle crash,” please elaborate with regard to exactly
what “you” did in the course of such “investigating;”

15
b. “That’s correct” to the question of “Paul Williams entered
the crash scene,” please elaborate with regard to what exactly
were the parameters of the “crash scene” that you testified
someone actually “entered;”

c. “Correct” to the question of “Mr. Williams was advised not

to take any further pictures and to leave the area,” please
elaborate with regard to exactly who so “advised” and by what
lawful authority, if you know, was Williams so advised;19

d. “Correct” to the question about Paul Williams replying

“[d]on’t start, just worry about your scene,” please elaborate
with regard to what was the tone and demeanor of such reply;

e. “Correct” to the question about Paul Williams replying

“[i]t’s my First Amendment to be here and I’m on private
property,” please elaborate on whether you know if any
consideration was given to Williams’ alleged statement and, if
none was given, why not.

f. “Yes” to the question about, after Paul Williams allegedly

stated “[i]t’s my First Amendment to be here and I’m on
private property,” “officers made contact with the owner of
the property * * * ,” please elaborate with regard to 1)
exactly who made contact with the owner, 2) how such contact
was initiated and accomplished, 3) what such contact consisted
of;

g. “Correct” to the question about “[y]ou were escorting Mr.

Williams away from the scene,” please elaborate on exactly
where Mr. Williams was when you began “escorting” him, how it
came to be that were you were “escorting Mr. Williams,” how
you were “escorting Mr. Williams,” and what, if anything, Mr.
Williams was doing throughout the time you were “escorting”
him;

h. “Yes” to the question that “he tried again to reenter the

area,” please elaborate on exactly where he was when he “tried
again to reenter” and exactly how “he tried again to reenter;”

i. “Correct” to the question that “he struck your left arm and
said: Don’t put your fucking hands on me,” please elaborate
with regard to whether he also struck you in your throat,
groin, shin, chest, eye, facial or head areas, or anywhere
else and, if so, what injury, if any, did you sustain. As
well, please also elaborate further on whether you believed
that, in allegedly striking your arm and stating “don’t put

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 your fucking hands on me,” it was his conscious object to
cause you bodily injury and, if so, describe the facts, if
any, upon which you rely as the basis for that belief;

j. “Correct” to the question that, when “he struck your left

arm, it caused a stinging sensation in your arm * * * ,”
please elaborate with regard to whether

1) you had ever before stated that such alleged strike

“caused a stinging sensation;”

2) the approximate dates when such statement was first made

and any time thereafter;

3) whether such statement(s) was made in writing and/or

orally;

4) to whom and in what context such statement(s) was made;

5) provide a copy of any writing wherein such statement has

been made;

6) whether you had sought any medical attention for the

“stinging sensation;”

7) whether the descriptive phrase “stinging sensation” was

first stated to Danny Ljungberg by you or to you by him;
k. “Yes” to the question that “Mr. Williams was guided to the
ground and as you were attempting to place him under arrest,
he was struggling with you,” please elaborate with regard to
how Mr. Williams was “guided to the ground;”

l. “Yes” to the question of “[u]sing physical force,” please

elaborate with regard to exactly what was the “physical force”
that you testified that he was actually using.

INTERROGATORY 13 If the answer to the preceding Interrogatory

is affirmative, state whether you had any communication with
Danny Ljungberg regarding your testimony and, if so, please
elaborate with regard to:

(a) the date of the communication;

(b) the contents of the conversation; and
(c) if in writing, attach a copy.

ANSWER:

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INTERROGATORY 14 State whether, on June 27, 2018, you were
operating a vehicle from a fleet of the Jackson Township Police
Department? If the answer to this interrogatory is affirmative,
please elaborate with regard to what is the vehicle
identification, whether the vehicle was equipped with a Mobile
Video/Audio Recorder (MVR) and whether such MVR was operating as
intended.

ANSWER:

INTERROGATORY 15 State whether, to your knowledge, all

vehicles from a fleet of the Jackson Township Police Department,
that are equipped with Mobile Video/Audio Recorder (MVR), are
set to automatically begin recording upon activation of the
vehicle’s emergency lights.

ANSWER:

INTERROGATORY 16 State whether, on June 27, 2018, you

responded to a motor vehicle crash in the vicinity of 64 South
Hope Chapel Road, Jackson NJ? If the answer to this
interrogatory is affirmative, please elaborate with regard to
whether you were operating a vehicle from a vehicle fleet of the
Jackson Township Police Department at such time and did you
activate the vehicle’s emergency lights during such response.

ANSWER:

INTERROGATORY 17 Provide the names and addresses of any

individual who supplied information used to prepare your
responses to these Interrogatories, and for each person,
identify the specific interrogatories for which she/he provided
information.

ANSWER:

INTERROGATORY 18 State the full name and address of all

persons whom you know to be eyewitnesses to, and/or have
knowledge of, the matters that are the subject of this action,
their relationship to you and their interest in this action and
summarize what you believe they witnessed and/or have knowledge
of.

ANSWER:

CERTIFICATION

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 I have read the foregoing answers to Interrogatories and
they are true, accurate, and complete and all documents
submitted are originals or true copies of the original documents
in my possession or control.
I hereby certify that the foregoing statements made by me
are true. I am aware that if any of the foregoing statements
made by me are willfully false, I am subject to punishment.

DATED:
Richard Bosley

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