[brief] Plaintiff Was Statutorily Barred From Holding Her Job With [...] As A Matter Of Law.  New Jersey law bars Plaintiff from providing care to vulnerable individuals in [...]’s group homes.  New Jersey law provides that “an individual shall be disqualified from employment” with group homes, including those operated by [...], if that individual has been convicted of “[a] crime or offense involving the manufacture, transportation, sale, possession or habitual use of a controlled dangerous substance. ”  N.J. STAT. ANN. § 30:6D-64(b)(1)(c); see also Davis v. Devereux Found., 209 N.J. 269, 295 (2012) (citing the Statute to support the assertion that “[f]acilities are required to conduct background checks, and are prohibited from hiring individuals who have committed one in a list of enumerated crimes. ”); N.J. ADMIN. CODE § 10:44A-2.4 (emphasis added).  The Statute makes clear that an individual convicted of such conduct under the laws of other states is also similarly disqualified from providing care to vulnerable individuals.  N.J. STAT. ANN. § 30:6D-64 (disqualifying for convictions “in any other state …which, if committed in New Jersey, would constitute any of the crimes or disorderly persons offenses described”); see also N.J.  ADMIN. CODE §10:44A-2.4.  Plaintiff was a heroin dealer and pleaded guilty to three counts related to dealing heroin.  (Appx 525-27 ¶¶21-30; Appx 114 at 67:16-23).  Accordingly, the Statute is clear: Plaintiff’s convictions for dealing and possessing a controlled dangerous substance disqualified her from ever working with vulnerable individuals in any of [...]’s group homes.  Plaintiff’s failure to cooperate with [...] by lying on her employment application further disqualified her from continuing her employment with [...].  The Statute also requires that applicants “consent to, or cooperate in, securing of a criminal history record background check. ”  N.J. STAT. ANN. §30:6D-64(c).  The Statute is crystal clear about the individual consequences for failing to cooperate: the person shall be immediately removed from the person’s position and the person’s employment shall be terminated . . .  Id. at 30:6D-64(d) (emphasis added).  The Trial Court properly found “that statutorily . . . [Plaintiff] never should’ve had this job. ”  (Appx 572 at 22:19-25).  The Trial Court further appropriately noted that Plaintiff “lied . . . many times under oath about the fact that she had a criminal conviction. ” (Appx 572 at 22:19-25).  First, Plaintiff lied on her Criminal Disclosure Statement when she answered “no” to the question, “Have you ever been convicted of a crime?” (Appx 76; Appx 116 at 75:25-76:12).  Plaintiff lied again when she signed the Employee Statement attesting that she had never been convicted of any “[c]rime(s) involving controlled substances or other like offenses. ” (Appx 078; Appx 117-18 at 79:7-12, 82:14-18).  Finally, under penalty of perjury, Plaintiff signed a statement swearing that she had no criminal offense involving a controlled substance, as required under New Jersey law.  (Appx 80-83; Appx 120 at 95:12-17, 96:1-4); see also N.J. STAT. ANN. § 30:6D-64(e) (requiring “a sworn statement attesting that the individual has not been convicted of any crime or disorderly persons offense as described in this act. ”).  B.