UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW JERSEY

WILSON J. CAMPBELL, 

Plaintiff,

vs.

THE SUPREME COURT OF NEW 

JERSEY; JUDGE MAURICE GALLIPOLI 

(Assignment Judge for Hudson County, 

Superior Court of New Jersey, in his 

individual capacity); CANDACE MOODY 

(Disciplinary Counsel, for Advisory 

Committee on Judicial Conduct, in her

individual capacity), JOHN TONELLI 

(Executive Director of the Advisory 

Committee on Judicial Conduct, in his 

individual capacity); and JOHN DOE 

EMPLOYEES I-X (fictitious names 

provided, actual names presently unknown). 

Defendants.

Civil Action No.____________

Hon.______________________

COMPLAINT

AND JURY TRIAL DEMAND

Plaintiff Wilson J. Campbell by way of complaint against Defendants in this matter, 

hereby states: 

INTRODUCTION

1. Judge Maurice Gallipoli (“Judge Gallipoli”) unlawfully sought to remove 

Wilson Campbell (“Campbell” or “Plaintiff”), from his position as a municipal court judge for 

engaging in a consensual dating relationship with Ann Kirolos (“Kirolos”), a former college 

professor, employed by the judiciary. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 1 of 34 PageID: 1
2

2. The New Jersey Supreme Court’s Policy on Consensual Dating in the 

Workplace (“Policy on Consensual Dating”)1allowed such relationships between judges, 

supervisors and judiciary employees. 

3. Judge Gallipoli nevertheless demanded Campbell’s resignation based on the 

relationship with Kirolos, but Campbell chose not to resign. Judge Gallipoli stated that he 

was angered by the relationship and he thought Campbell should “pack up his bags and 

leave.”

4. Of significance to Judge Gallipoli was the fact that Campbell, a black male, 

engaged in a dating relationship with Kirolos, a white female. 

5. At the request of Judge Gallipoli, Candace Moody (“Moody”), Disciplinary 

Counsel for the Advisory Committee on Judicial Conduct (“ACJC”), filed an ethics complaint 

against Campbell alleging that Campbell’s relationship with Kirolos violated judicial canons. 

6. Moody was aware that Kirolos was white and that Campbell was black at 

the time she filed her complaint. Moody’s complaint against Campbell on its face stood in 

direct contradiction to the Policy on Consensual Dating. 

7. On December 16, 2009 during the ACJC hearing on the matter Judge Nesle 

Rodriguez (“Judge Rodriguez”), Chief Judge of the Jersey City Municipal Court, testified that 

dating relationships were allowed between members of the judiciary in New Jersey and that 

she could not point to any policy that Campbell violated based on the relationship. 

 

1 The Policy on Consensual Dating is more than a decade old with its most recent update on October 29, 2008, 

by Judge Glenn Grant, Administrative Director of Courts. The exact same Policy on Consensual Dating was 

approved by Judge Phillip Carchman on July 3, 2007, Administrative Director of Courts; and approved by Judge 

Richard Williams, Administrative Director of Courts in May 2000 and April 2004. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 2 of 34 PageID: 2
3

8. When asked what would happen to Campbell if he chose not to resign in 

response to Judge Gallipoli’s demands, Judge Rodriguez testified, “Perhaps consequences that 

would result wouldn’t be worth the impact to his career.”

9. Judge Gallipoli wanted to punish Campbell for his relationship with Kirolos 

and Moody aided Judge Gallipoli in this effort by misusing the ACJC complaint process. 

10. Judge Gallipoli and Moody, acting under color of law, discriminated against 

Campbell based on his race, sex and marital status in violation of his rights under the New 

Jersey Law Against Discrimination (“LAD”), the New Jersey State Constitution, the United 

States Constitution and federal law for engaging in a consensual dating relationship with 

Kirolos. 

PARTIES

11. Plaintiff Wilson J. Campbell is an adult black male residing in St. Thomas, 

U.S. Virgin Islands. During part of the time period relevant to this suit Campbell served as a 

municipal court judge in Jersey City and an attorney in private practice in New Jersey. 

12. Defendant, the New Jersey Supreme Court is a governmental entity of the 

State of New Jersey with its offices located at the Hughes Justice Complex, 25 Market Street, 

Trenton, New Jersey. 

13. Defendant Judge Maurice Gallipoli is an adult white male whose business 

address is the Brennan Courthouse, 595 Newark Avenue, Jersey City, New Jersey. At all 

relevant times, Judge Gallipoli served in a management capacity as the Assignment Judge of 

the Superior Court in Hudson County acting under the direction and authority of the Supreme 

Court of New Jersey. In this capacity Judge Gallipoli had supervisory authority over 

Campbell. Judge Gallipoli is sued in his individual capacity. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 3 of 34 PageID: 3
4

14. Defendant Candace Moody is an adult white female whose business address 

is Hughes Justice Complex, 25 Market Street, Trenton, New Jersey. At all relevant times, 

Moody served as the Disciplinary Counsel for the Supreme Court of New Jersey. In this 

capacity the Supreme Court of New Jersey gave Moody the authority to file formal 

disciplinary charges against all judges in the State of New Jersey. She is sued in her 

individual capacity. 

15. Defendant John Tonelli (“Tonelli”) is an adult white male whose business 

address is the Hughes Justice Complex, 25 Market Street, Trenton, New Jersey. At all 

relevant times, Tonelli served in a management capacity as the Executive Director of the 

Advisory Committee on Judiciary Conduct for the Supreme Court of New Jersey. In this 

capacity he supervised Moody, investigated complaints against judges, and aided Moody in 

the filing of ethics complaints. He is sued in his individual capacity. 

16. Defendants John Does 1 – 10 are adult individuals, names and addresses 

currently unknown, who at all relevant times were judiciary employees under the direction 

and authority of then New Jersey Supreme Court who participated in the events below. They 

are sued in their individual capacities. 

17. Article 6, Section 2, Paragraph 3 of the Constitution of the State of New 

Jersey provides in pertinent part, “The Supreme Court shall make rules governing the 

administration of all courts in the State and, subject to the law, the practice and procedure in 

all such courts.”

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 4 of 34 PageID: 4
5

18. The Supreme Court is obligated under the Constitution of the State of New 

Jersey to exercise its rule-making authority over all courts, judges and lawyers in the State.

19. The New Jersey Rules of Court 2:15 provides in relevant part that:

To implement N.J.S.A. 2B:2A-10, providing for suspension prior to hearing, 

and to assist otherwise in fulfilling the administrative responsibilities of the 

court, the Court establishes a committee of this Court to be known as the 

Advisory Committee on Judicial Conduct. 

20. The Supreme Court has given the ACJC unfettered discretion to determine 

which complaints the ACJC chooses to file against judges without meaningful oversight. 

21. Under New Jersey’s Constitution and the United States Constitution, 

intimate decisions relating to personal matters between consenting adults are fundamental 

privacy rights protected under the law. Adverse action in response to exercising such 

fundamental rights is a violation of public policy.

JURISDICTION AND VENUE

22. This action arises under 42 U.S.C. §§ 1981, 1985, and 1988 – laws of the 

United States. As part of the same case and controversy, Plaintiff also asserts related and 

intertwined state-law claims for violation of civil rights under N.J.S.A. 10:5-1 et seq., 

N.J.S.A. 59:1-1, et seq., and civil conspiracy.

23. This Court has subject matter jurisdiction over this action under 28 U.S.C. 

§§ 1331, 1332, 1343(a), and 1367.

24. Venue in this district is proper under 28 U.S.C. § 1391(b) because a 

substantial part of the events giving rise to Plaintiff’s claims occurred in this district. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 5 of 34 PageID: 5
6

FACTUAL ALLEGATIONS

A. Background

25. Campbell is a black male and former municipal court judge in Jersey City, 

New Jersey. He was a part-time municipal court judge from October 2007 to October 2009. 

26. Campbell’s position as a municipal court judge required him to serve on the 

bench four nights per week and to be “on call” at various times throughout the year. 

27. As a municipal court judge, Campbell was subject to the employment 

policies and procedures dictated by the Supreme Court of New Jersey for all judges in the 

State of New Jersey.

28. As a municipal court judge, Campbell was subject to disciplinary 

employment policies of the Supreme Court of New Jersey that were enforced by the Supreme 

Court and the ACJC.

29. Campbell also served as an attorney in New Jersey during the relevant time 

periods where he represented numerous business clients in private practice.

30. In April 2008, Campbell became involved in a consensual dating 

relationship with Kirolos, a white female, judiciary employee. 

B. Judge Gallipoli Demands Campbell’s Resignation Before an Investigation

31. Judge Gallipoli, the Assignment Judge for Hudson County, learned about 

the dating relationship between Campbell and Kirolos in June 2008 and demanded that 

Campbell, immediately resign from the bench. 

32. By the time Judge Gallipoli learned of the relationship between Campbell 

and Kirolos in June 2008, the relationship had already ended. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 6 of 34 PageID: 6
7

33. On or about June 30, 2008, Judge Gallipoli informed Campbell that if he did 

not resign, Judge Gallipoli would make facts related to the relationship public and seek formal 

charges through the ACJC to adversely affect Campbell’s career and business opportunities.

34. On or about June 30, 2008, Campbell advised Judge Galliopli that Campbell

would not resign from the bench based on his past dating relationship with Kirolos, which did 

not violate the judiciary policy. 

35. The Policy on Consensual Dating instituted in May 2000 allowed dating 

relationships between judges, supervisors and judiciary employees. 

36. Even though dating relationships were allowed between judges and 

judiciary employees, Judge Gallipoli acted in concert with Moody and members of the ACJC 

to punish Campbell based on his race, sex and marital status for engaging in the relationship 

with Kirolos. 

37. When Campbell informed Judge Gallipoli that Campbell would not resign, 

Judge Gallipoli contacted Judge Phillip Carchman, Administrative Director of Courts, and 

stated in an e-mail, “Anticipating he [Judge Campbell] will not resign, I think at the very least 

a suspension is called for pending a full investigation and the resolution of any and all charges 

that may be brought against him.” (E-mail from Judge Gallipoli to Judge Carchman, dated 

June 30, 2008, with a copy to Chief Justice Stuart Rabner).2

38. On or about June 30, 2008 Judge Gallipoli temporarily suspended Campbell

from his position as a municipal court judge when Judge Gallipoli ordered Campbell not to 

return to work. 

 

2 Even in cases where judges are charged with sexual harassment, there is no automatic suspension pending an 

investigation. Kirolos never alleged that Campbell sexually harassed her and Kirolos never filed a complaint 

against Campbell based on the relationship or for any other reason. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 7 of 34 PageID: 7
8

39. The suspension took place without notice or hearing and affected 

Campbell’s property interest in his position as a municipal court judge where he was 

appointed to the bench for three years by the City of Jersey City from October 2007 to 

October 2010.

40. Judge Galliopli then sent a memorandum to Judge Carchman which stated, 

“I suggested to Judge Campbell that he should seriously consider resignation. As previously 

advised, he has declined that invitation and has informed me that he intends to remain as a 

judge of the court... I assume a complaint against Judge Campbell will be filed with the 

ACJC.” (Memorandum from Judge Gallipoli to Judge Carchman, dated July 1, 2008).

C. Tonelli Conducts a Sparse Investigation that Does Not Support Campbell’s

 Resignation

41. The ACJC conducted an investigation in the matter and interviewed a total 

of three witnesses, which did not include Campbell. 

42. The first two witnesses, Kirolos and Rebecca Mason (“Mason”), Assistant 

Court Director of the Jersey City Municipal Court, were interviewed on September 26, 2008.

43. Kirolos informed the ACJC that the relationship was consensual. 

44. Kirolos and Mason informed the ACJC that Campbell was not Kirolos’s 

supervisor. (Statement of Kirolos to ACJC, dated September 26, 2008, Page 6, Line 21 – 23), 

(Statement of Mason to ACJC, dated September 26, 2008, Page 11, Lines 15 – 19). 

45. The ACJC took no substantive action for three months.

46. Tonelli interviewed the ACJC’s last witness, Judge Gallipoli, on January 14, 

2009. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 8 of 34 PageID: 8
9

D. Judge Gallipoli Reaffirms His Desire to Force Campbell’s Resignation

47. Judge Gallipoli made it unequivocally clear to Tonelli that Judge Gallipoli 

wanted Campbell off the bench based on Campbell’s relationship with Kirolos. Judge 

Gallipoli stated:

I’m not so sure he [Judge Campbell] was as contrite as I would have liked him 

to be and I know, quite frankly, that I thought the easy way out of this for 

everyone concerned was for him to resign and I put it to him that I thought he 

should seriously consider resigning.

(Statement of Judge Gallipoli to ACJC, dated January 14, 2009, Page 7, Line 23 – Page 8, 

Line 3) (emphasis added).

48. Judge Gallipoli again reiterated to Tonelli:

“... the easiest way for everyone to just get on with their life, him and her 

included was for him to pack up his bags and leave...And when I say, I 

suggested it [resignation] to him [Judge Campbell], suggested is not really 

expressing how strongly I put it to him.”

(Statement of Judge Gallipoli to ACJC, dated January 14, 2009, Page 10, Line 23 –

Page 11, Line 2)(emphasis added).

49. Judge Gallipoli wanted to prohibit consensual dating relationships between 

judiciary employees even though such relationships were allowed under the Policy on 

Consensual Dating.

50. Tonelli asked Judge Gallipoli if he was aware of a particular policy in 

Jersey City Municipal Court that prohibited judges from engaging in dating relationship with 

court employees. Judge Gallipoli stated: 

I don't know whether there was a formal policy but I dare say the City must 

have some sort of a policy over there and, quite frankly, you don't really need a 

policy that's written out and spelled out...It's not unless you are deaf, dumb 

and blind you shouldn't be doing this.3 

 

3 Although Judge Gallipoli suggest that judges who engage in dating relationships with judiciary employees have 

a moral or mental defect, it should be noted that the Honorable Justice William Brennan of the United States 

Supreme Court wed his secretary shortly after his wife passed away. Justice Brennan, a native of New Jersey 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 9 of 34 PageID: 9
10

(Statement of Judge Gallipoli to ACJC, dated January 14, 2009, Page 12, Lines 16 – 22) 

(emphasis added).

51. Tonelli also asked Judge Gallipoli if he was aware of a judiciary policy that 

prohibited judges from engaging in dating relationships with judiciary employees. The 

colloquy went as follows:

Q In terms of any policies in the judiciary, are you aware of any that deals 

directly on this subject [judges dating court employees]?

A I mean, yes. I mean, I don’t think you should be doing this at all. I 

mean all you have to do is read a couple of cases or basically read the 

law journal to see how judges have gotten in trouble in the past. It sort 

of like should be the clue that this is not the way to go. 

 

(Judge Gallipoli Statement to ACJC, dated January 14, 2009, Page 12, Line 23 – Page 13, 

Line 4) (emphasis added).

52. At the time Judge Gallipoli gave that response to Tonelli, the Policy on 

Consensual Dating was dated October 29, 2008. The prior Policy on Consensual Dating was 

dated July 3, 2007. The Policy on Consensual Dating contained the exact same language 

which had been in existence since May 2000 and it allowed for such relationships. There was 

also no policy in the Jersey City Municipal Court that prohibited such relationship between 

judges and judiciary employees.

53. Judge Gallipoli presided on the Superior Court bench for more than ten (10) 

years and as Assignment Judge for Hudson County for four (4) years at the time he learned of 

Campbell’s relationship. Judge Gallipoli knew or should have known of the Policy on 

Consensual Dating. 

54. As the Assignment Judge in Hudson County, Judge Gallipoli held a position 

of management in the judiciary which required him to adhere to the policies of the New 

 

and one of the most respected jurists on the U.S. Supreme Court, worked daily with his wife who served in her 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 10 of 34 PageID: 10
11

Jersey Supreme Court whether those mandated policies fit with Judge Gallipoli’s personal 

beliefs or not. 

E. Judge Gallipoli Ignores the Supreme Court’s Policy and Seeks Campbell’s 

 Resignation

 

55. The New Jersey Supreme Court placed the Policy on Consensual Dating 

directly in its Judiciary Policy Statement on Equal Employment Opportunity, Affirmative 

Action and Anti-Discrimination (“EEO Policy Statement”). 

56. The EEO Policy Statement is a two page document that begins with the 

following directive:

The Chief Justice and Supreme Court of New Jersey declare the following to 

be the policy of the New Jersey Judiciary in order to ensure equal opportunity 

for all Judiciary employees and applicants for employment, and in order to 

ensure that all court users, volunteers, attorneys, litigants, witnesses or others 

who come in contact with the court system are treated in a non-discriminatory 

manner with civility, dignity, and respect. All who serve in the Judicial 

Branch are responsible for implementing this policy. 

(EEO Policy Statement, dated July 3, 2007 and October 29, 2008).

57. Judge Gallipoli incorrectly asserted that a dating relationship between a 

judge and a judiciary employee was inappropriate, prohibited and not allowed by the New 

Jersey Supreme Court. However, the Policy on Consensual Dating begins with the statement, 

“Consensual dating relationships between Judiciary employees are generally not the 

Judiciary’s business.” (EEO Policy Statement, July 3, 2007 and October 29, 2008)(emphasis 

added).

58. The Policy on Consensual Dating concludes with the statement:

For justices, judges and judiciary employees subject to the New Jersey Tort 

Claims Act, N.J.S.A. 59:1-1, et seq., failure to give proper notice to the 

supervisor’s immediate superior [of the relationship] may result in the denial of 

legal representation and indemnification by the State in the event that a 

 

capacity as his secretary for numerous years until he retired from the bench. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 11 of 34 PageID: 11
12

discrimination or sexual harassment lawsuit is filed in connection with the 

relationship.4

(EEO Policy Statement, dated July 3, 2007 and October 29, 2008)(emphasis supplied).

59. Nowhere does the policy prohibit consensual dating relationships between

judges and judiciary employees nor does it provide additional consequences for those who 

choose to keep such relationships private, since to do so would be a violation of State privacy 

rights.5

60. Judge Gallipoli treated Campbell different from Kirolos, a female, in light 

of the dating relationship by demanding Campbell’s resignation. Judge Gallipoli stated, 

“Quite frankly, you know, this was a woman who worked at the Court and she shouldn’t get 

fired for this relationship.” (Statement of Judge Gallipoli to ACJC, dated January 14, 2009, 

Page 10, Lines 14 – 15).

61. Judge Gallipoli could cite no authority to warrant Campbell’s resignation, 

but he nevertheless sought Campbell’s resignation. In Judge Gallipoli’s interview with the 

ACJC the following dialogue occurred:

 

4 This language grants the judge or supervisor the option to maintain privacy or report the relationship with the 

understanding that some perils may result from failing to report the relationship if a claim of sexual harassment 

or discrimination is made. The language in the policy was careful not to punish consenting adults or require 

them to obtain the “blessings from the government” before engaging in such relationships. As the United States 

Supreme Court in Lawrence v. Texas, 539 U.S. 558, 574 (2003), stated, “It is the promise of the Constitution 

that there is a realm of personal liberty which the government may not enter. Id. at 578 (citing Planned 

Parenthood Southeastern Pa. V. Casey, 505 U.S. 833, 847 (1992). Individual decisions of married and 

unmarried persons concerning the intimacies of their physical relationship are a form of “liberty” protected by 

the Due Process Clause of the Fourteenth Amendment. Id. (citations omitted). The right to privacy is a 

fundamental right protected by the New Jersey State Constitution. In re Martin, 90 N.J. 295, 318 (1982). The 

right to privacy is one of the “natural and inalienable rights” recognized by the state constitution. Hennessey v. 

Coastal Eagle Point Oil Co., 129 N.J. 81, 96 (1992). 

5 The New Jersey Supreme Court has explicitly articulated and broadly defined a right of privacy that protects 

individuals from unwarranted intrusion into matters of intimate personal concern. See In re Grady, 85 N.J. 235, 

249-50 (1981). Employer policies prohibiting consensual dating relationships violate an employees’ state 

constitutional right to privacy. Slohonda v. United States Parcel Service, Inc., 193 N.J. Super. 586 (App. Div. 

1984). Voluntary dating relationships in the workplace do not constitute workplace discrimination. See Erickson 

v. March, 117 N.J. 539 (1990). Intimate relationships in the workplace do not constitute “misconduct” in the 

workplace simply because they involve a supervisor and subordinate. See K.S. v. ABC Professional Corp., 330 

N.J. Super. 288 (App. Div. 2000). 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 12 of 34 PageID: 12
13

Q. In the past four years since you've been assignment judge, have you 

had any other occurrences whether it was with this judge [Judge 

Campbell] or any other judge under your authority that has done 

something similar to this?

A. Yes, unfortunately and I guess that's going to be the second interview.

Q. My question is how did you handle that matter?

A. The same way. With a report, basically trying to get the matter resolved 

although in the one we're going to talk about for a lot of different 

reasons I guess I didn't suggest that the person [Judge DeBello] resign. 

But in this particular case I thought that the person [Judge Campbell] 

should resign. It was a part time position and I just thought it was 

totally inappropriate. Not that I don't think the other situation 

[involving Judge DeBello] that we're going to discuss was in any way 

more appropriate.

(Statement of Judge Gallipoli to ACJC, dated January 14, 2009, Page 13, Lines 5 – 20).

Diagrams of Discrimination by Judge Gallipoli

Judge DeBello (White, Male) Judge Campbell (Black, Male)

Warned regarding Policy No Warning

No Demand for Resignation when it was 

clear that Judge DeBello violated policies and 

continued to violate policies after being 

warned

Demanded Resignation immediately without 

legal or factual basis 

No Suspension Temporary suspension by Judge Gallipoli 

Judge Gallipoli made no Suggestion that 

actions would be made public or would 

damage career and Judge Gallipoli kept the 

matter secret for several months until Judge 

DeBello repeated policy violations

Judge Gallipoli threatened Campbell that if 

he did not resign the matter would become 

public 

Interviewed regarding policy violations No interview opportunity given to Judge 

Campbell

Resolved case in less than six (6) months Took approximately two years to reach a 

decision. Issued final decision days before 

State of Limitations after State placed on 

Notice of Campbell’s intent to file suit

Judge DeBello received a Censure, one 

level below Suspension, for his actions but 

Judge Gallipoli Did Not Demand Judge 

DeBello’s Resignation

Judge Campbell received a Private 

Reprimand, the lowest form of public 

discipline, but Judge Gallipoli Demanded 

Campbell’s Resignation

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 13 of 34 PageID: 13
14

Levels of Punishment for Judges Highest to Lowest

Removal from bench

Suspension from bench

Censure

Admonishment

Public Reprimand

62. Judge Gallipoli stated that he handled the matters the same, when in fact he 

first warned Judge DeBello and only made reports to the ACJC after Judge DeBello continued 

to violate policies of the judiciary.6Judge Gallipoli also never sought Judge DeBello’s 

resignation. Judge Gallipoli did not handle the matters involving Judge DeBello and Campbell 

“the same way,” due in part to Campbell’s race.

F. Moody Aids Judge Gallipoli in Punishing Campbell by Filing Formal 

 Charges Against Campbell for Not Submitting His Resignation

63. The ACJC treated Campbell different based on race when the ACJC 

interviewed Judge DeBello, but did not interview Judge Campbell before filing charges. 

64. The ACJC treated Campbell different based on race and sex when the ACJC 

interviewed Kirolos regarding her relationship with Campbell, but did not interview Campbell

regarding the relationship. 

65. On February 2, 2009, the ACJC filed an ethics complaint against Campbell 

which charged:

By engaging in an intimate relationship with a subordinate municipal court 

employee over whom he exercised supervisory control Respondent violated 

Canons 1 and 2A of the Code of Judicial Conduct in that he did not maintain 

 

6

Judge DeBello was censured for using his judiciary e-mail in violation of the Judiciary IT Policy by sending 

messages of an intimate and personal nature to his former law clerk. Judge DeBello also made an unsolicited 

contact with a person who appeared before his court to obtain employment for his former law clerk. Judge 

DeBello gave misleading responses under oath regarding the relationship and the use of his judiciary e-mails. 

Campbell did not commit any of the acts alleged against Judge DeBello. Judge DeBello was never charged with 

an ethics complaint for his relationship with his former law clerk. See In re DeBello, Order D-13 September 

2009.

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 14 of 34 PageID: 14
15

high standards of conduct and did not act in a manner that promotes confidence 

in the integrity and impartiality of the Judiciary.

7

(ACJC Complaint against Campbell, Paragraph 9, dated February 2, 2009.)

66. At all times before and after the filing of the ACJC’s complaint, Judge

Gallipoli, Moody, and Tonelli knew or should have known that in the history of the New 

Jersey Judiciary no judge had ever been charged with an ethics complaint for a consensual 

dating relationship with a judiciary employee following the issuance of the Policy on 

Consensual Dating in 2000, even though a number of judges had engaged in such 

relationships.

67. In April 2009, Campbell learned of the less favorable treatment he received 

from Judge Gallipoli and members of the ACJC based on race, sex and marital status.

68. Campbell placed the State of New Jersey on notice of his intention to file 

suit within a timely manner, pursuant to the New Jersey Tort Claims Act, 59:1-1, et seq., but 

Campbell gave the Defendants almost two years to take corrective action before Campbell 

decided to file suit. 

G. The ACJC Aids Judge Gallipoli in Punishing Campbell for Not Submitting 

 His Resignation

69. After receiving notice of Campbell’s intent to file suit, Judge Gallipoli, 

Moody, Tonelli and John Does I-X, acted in concert to intentionally delay the resolution of 

the ACJC complaint filed against Campbell in retaliation to cause Campbell prolonged 

damage to his reputation, emotional distress, loss of business opportunities and other 

damages. 

 

7 No judicial canon prohibits dating relationships between judges and judiciary employees, nor do the canons 

suggest that such relationships create an appearance of impropriety. The Policy on Consensual Dating allowed 

dating relationships between judges, supervisors and judiciary employees. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 15 of 34 PageID: 15
16

70. The diagram below provides an example of the judiciary’s expedient 

resolution of other judiciary complaints compared to Campbell’s case.

Judge Complaint Presentment SC Order8Final9 Days

J. Rivera-Soto May11,2007 Jul. 11, 2007 Jul. 20,2007 Jul. 20, 2007 70

J.Sibly Sep. 12,2007 May 19, 2008 Jun. 16, 2008 Jun. 16, 2008 308

J.McElroy Mar. 7, 2008 Jul.30,2008 Sep. 29, 2008 Sep.29,2008 206

J. Rodriguez Mar.12,2008 Jul.30, 2008 Sep.22,2008 Sep.22,2008 194

J.Sasso Mar.13,2008 Mar. 2009 Jun. 2, 2009 Jun.2, 2009 446

J.Toth Jan. 5, 2009 Jul. 14, 2009 Sep. 9, 2009 Sep.9, 2009 247

J. Boggia Jan. 5, 2009 May 14, 2009 Jun. 1, 2009 Jul. 27, 2010 568

J.Campbell Feb. 2, 2009 Feb. 25, 2010 Apr.13, 2010 Jan.28,201110 725+

J.DeBello Mar. 4, 2009 Sep. 21, 2009 Nov. 16,2009 Nov.16, 2009 257

J. Citta Apr. 1, 2009 Jan. 27, 2010 Mar. 8, 2010 Mar. 8, 2010 341

J. Covery Apr. 1, 2009 Jan. 27, 2010 Mar. 8, 2010 Mar. 8, 2010 341

71. The ACJC acknowledged that the relationship between Campbell and 

Kirolos was consensual. The ACJC acknowledged that the Policy on Consensual Dating 

allowed such relationships, and then relied on In re Hyland, a case that predated the Policy on 

Consensual Dating by fifteen (15) years to suggest that Campbell’s relationship was 

inappropriate.11 

H. Moody Aids Judge Gallipoli in Punishing Campbell by Placing Campbell 

 in a False Light for Not Submitting His Resignation

 

72. Kirolos never alleged that Campbell sexually harassed her and Kirolos

never filed a complaint of sexual harassment against Campbell. Kirolos admitted that her 

 

8

“ SC Order” is an abbreviation for the New Jersey Supreme Court Order issued on the matter or the Order to 

Show Cause.

9

“Final” refers to the conclusive disposition on the matter by the New Jersey Supreme Court.

10 Decision rendered less than a week prior to the statute of limitations in the case after the Supreme Court was 

placed on notice of Campbell’s intent to file suit. 

11 The ACJC relied on the case of In re Hyland, 101 N.J. 631 (1985) to support its recommendation for a public 

reprimand against Judge Campbell, but failed to note that Hyland had never been adopted by the New Jersey 

Supreme Court. In Hyland it was alleged that Judge Hyland sexually harassed his secretary for several years, 

traded sex toys with her in his chambers and ultimately fired her when she chose to end the relationship. No such 

claims were made against Judge Campbell. It appears that at the time of Hyland the New Jersey Supreme Court 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 16 of 34 PageID: 16
17

relationship with Campbell was consensual and that she was disappointed when the 

relationship ended. 

73. In the ACJC Complaint filed against Campbell, Moody acted with reckless 

disregard for the truth in an effort to intentionally damage Campbell’s professional reputation 

by suggesting that Kirolos overdosed on medication and required treatment as a direct result 

of her relationship with Campbell.

74. Moody knew that Kirolos’s supervisor told Kirolos that if she did not go to 

the hospital “no one would believe the whole thing [relationship with Judge Campbell] 

happened.” (Statement of Kirolos to ACJC, dated September 26, 2008, Page 11, Line 1 – 4). 

Moody also knew that Kirolos went to the hospital and was sent home the same evening with 

no treatment and no finding that Kirolos needed medical attention.

75. Moody in her complaint erroneously suggested that Campbell caused 

Kirolos to “overdose on medication” because he ended the relationship in an effort to paint 

Campbell in a negative light. 

76. In fact, Campbell had no contact with Kirolos for days prior to the date on 

which Kirolos was alleged to have “overdosed” on medication. 

77. Moody’s unfair characterization of facts which she knew were not true 

placed Campbell in a false light and severely damaged Campbell’s reputation.

I. Moody Relies on Judge Gallipoli’s Statements and Denies Campbell an 

Interview 

78. At the Supreme Court hearing on the ACJC complaint filed against 

Campbell, the Supreme Court asked Moody if the ACJC ever interviewed Campbell to hear 

 

had not issued a formal policy on dating relationships concerning judges, superiors and subordinates. However, 

in 2000, the New Jersey Supreme Court issued the Policy on Consensual Dating authorizing such relationships. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 17 of 34 PageID: 17
18

his side of the facts before the ACJC filed its complaint against Campbell. The colloquy 

proceeded as follows:

Q. Ms. Moody in the rules that govern the actions of the ACJC there are at 

least two choke points as I refer to them where the ACJC is given the 

discretion, but not the obligation I understand to interview the 

respondent in a matter. The first one happens during the preliminary 

investigation period and the second one happens after the preliminary 

investigation period has occurred and in both instances the ACJC can 

notify the Respondent of what the allegations are, can provide the 

information of who the grievant is and can take a statement under oath 

from the Respondent. And, from what I gather that did not happen here 

at all.

A. You are correct Justice the ACJC did not get a statement from Mr. 

Campbell.

Q. Why?

A. Mr. Campbell had met with Judge Gallipoli three, perhaps four days 

following the incident which brought this relationship to the attention 

of the judiciary and given that fact and that Judge Gallipoli had spoken 

with Mr. Judge Campbell the ACJC was provided with Judge 

Gallipoli’s statement of that meeting and what had occurred the ACJC 

didn’t feel that it was necessary. They [the ACJC] had all the 

information that they needed.

(Statement of Moody during Supreme Court Oral Arguments on June 15, 2010)(emphasis 

added)(See http://njlegallib.rutgers.edu/supct/args/D_71_09.php, Time: 1:07:45 – 1:09:10).

79. The ACJC accepted the statements of Judge Gallipoli carte blanche and 

interviewed Judge Gallipoli without interviewing Campbell even though the ACJC knew that 

Judge Gallipoli sought Judge Campbell’s immediate removal from the bench and that Judge 

Gallipoli had told Campbell to “pack up his bags and leave” based on the relationship. 

(Statement of Judge Gallipoli to ACJC, dated January 14, 2009, Page 10, Line 25).

80. Although Moody stated to the Supreme Court that the ACJC had “all the 

information they needed” before Moody filed the complaint against Campbell, the facts show 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 18 of 34 PageID: 18
19

that the ACJC had not completed its investigation at the time Moody rushed to the court to 

lodge her complaint against Campbell. 

81. The ACJC had not received any documents regarding the work assignments 

of Kirolos and was awaiting documents from the Jersey City Municipal Court even after 

Moody filed the complaint against Campbell. 

82. Gerald Buccafusco (“Buccafusco”), Director of the Jersey City Municipal 

Court, wrote a letter to the ACJC in response to a request from the ACJC more than six weeks 

after the ACJC filed its complaint against Campbell. 

83. There Buccafusco stated, “I do not have any documentation of the 

assignment [of Kirolos] to any particular courtroom.” (Letter from Gerald Bucafucco to 

ACJC, dated March 12, 2009 and sent via facsimile). 

84. Thereafter Jennifer Endrzejewski (“Endrzejewski”) of the ACJC contacted 

Buccafusco by telephone on March 12, 2009 and asked Buccafusco to confirm that the Jersey 

City Municipal Court had no documents assigning Kirolos to Campbell’s court. 

85. After checking the courts records a second time, Buccafusco wrote a letter 

to Endrzejewski wherein Buccafusco stated, “This is a follow-up to our telephone 

conversation on March 12, 2009 with regard to the information I sent you via facsimile 

regarding Ms. [Kirolos]...To the best of my knowledge the information is complete and 

accurate. (Letter from Gerald Buccafusco to ACJC, dated March 13, 2009 and sent via 

facsimile). 

86. Tonelli lead the investigation for the ACJC and never interviewed Campbell 

or Kirolos’s supervisor, the chief bailiff. Tonelli also failed to research applicable policies of 

the New Jersey Supreme Court.

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 19 of 34 PageID: 19
20

87. The ACJC had not completed its investigation at the time Moody filed the

ethics complaint against Judge Campbell.

J. Moody was Aware of Married Couples in the Judiciary Yet Moody Sought 

 to Punish Campbell for a Dating Relationship Prior to Marriage

88. Although Judge Gallipoli pressed the ACJC to file a formal complaint 

against Campbell on the basis that Campbell’s relationship with Kirolos violated judiciary 

policy, Judge Gallipoli, Moody, Tonelli and members of the ACJC knew or should have 

known of a number of marriages between New Jersey judges, supervisors and subordinate 

judiciary employees. In fact, a judge who is a member of the New Jersey Supreme Court’s 

administrative staff is married to a subordinate judiciary employee.12

89. A clear fact in this regard is that Campbell and Kirolos were not married 

while married judges and judiciary employees were allowed to continue their relationships 

with other judiciary employees without being subjected to punishment or forced to resign 

from the bench.

90. Moody treated Campbell different based on marital status when Moody

filed charges against Campbell for having a consensual dating relationship with Kirolos away 

from court, but refused to file charges against a married judge who was found by a judiciary 

employee receiving oral sex in the judge’s chambers from another judiciary employee over 

whom that judge exercised “supervisory control.”13

 

12 The name of said judge and judiciary employee is not revealed here to protect privacy, but may be revealed at 

the appropriate time with names and positions of other married judiciary supervisor and subordinate employees 

who received no adverse action as a result of their relationships. 

13 The details of this matter are being withheld at this time since no public charges were filed against the judge, 

hereafter referred to as Judge “X.” How could the ACJC charge Campbell for a private relationship outside of 

the court on one hand, yet ignore the fact that a judge uses his chamber to engage in sex with a court employee 

on the other hand. The ACJC’s claim of its intent to enforce a judiciary policy is merely a cover for its intent to 

punish Campbell for not submitting to Judge Gallipoli’s demands for a resignation.

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 20 of 34 PageID: 20
21

K. Judge Rodriguez Confirms Judge Gallipoli’s Intent to Punish Campbell 

 For Not Submitting His Resignation

91. More than eighteen (18) months after the judiciary learned of the 

relationship between Kirolos and Campbell, Judge Rodriguez, the Chief Judge of Jersey City 

Municipal Court, could point to no policy that prohibited a judge from engaging in a 

consensual dating relationship with a judiciary employee. The examination went as follows:

Q What policy, written policy of the court, did [Judge] Wilson Campbell 

violate?

A. I can’t answer that specifically. I know that we have training and it 

seems clear as to what we can and can’t do in terms of being 

supervisors, but I can’t point to any one policy, written policy.

Q Can people date within the Judiciary?

A It’s my understanding they can date within the Judiciary.

(Testimony of Judge Rodriguez to ACJC, Transcript of ACJC Hearing, dated 

December 16, 2009)(Page 67, Lines 1 – 9) (emphasis added).

92. Judge Rodriguez was questioned why Judge Gallipoli asked Judge 

Campbell to resign. Judge Rodriguez testified:

Q Okay. But he [Judge Gallipoli] asked for his [Judge Campbell’s] 

resignation, isn’t that right?

A Yes.

Q All right. And did he [Judge Gallipoli] say why he [Judge Gallipoli] 

asked for that resignation?

A Because of the appearance of impropriety.14 He [Judge Gallipoli] also 

mentioned to then Judge Campbell that this was a part-time position for 

him [Judge Campbell]. He [Judge Campbell] worked at a big firm and 

that would not – if this became public, it would not be something that 

the firm may necessarily look favorably upon and it could affect his 

[Judge Campbell’s] career.

 

14 A detailed and thorough review of Judge Gallipoli’s Statement to the ACJC reveals that Judge Gallipoli never 

referenced the Policy on Consensual Dating and he never stated the relationship between Campbell and A.K. 

created an “appearance of impropriety.” 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 21 of 34 PageID: 21
22

(Testimony of Judge Rodriguez to ACJC, Transcript of ACJC Hearing, dated 

December 16, 2009, Page 79, Line 20 – Page 80, Line 2)(emphasis supplied). 

93. Judge Rodriguez, who was present during the interview between Judge 

Gallipoli and Judge Campbell, gave further assessment of what Judge Gallipoli expressed to 

Judge Campbell as follows:

Q Okay. Did he – and your explanation a moment ago suggested that, 

because this was a part-time position, can I use the term that Judge 

Gallipoli suggested it [Judge Campbell’s position on the bench] wasn’t 

worth the fight over it?

A Perhaps consequences that would result wouldn’t be worth the impact 

to his career.

(Testimony of Judge Rodriguez to ACJC, Transcript of ACJC Hearing, dated 

December 16, 2009, Page 80, Lines 7 – 12) (emphasis added). 

94. Judge Rodriguez was also asked about Judge Campbell’s response when 

questioned about his relationship with Kirolos as follows:

Q And, of course, once confronted – once questioned, Campbell was upright and 

honest with Judge Gallipoli that particular day, isn’t that right?

A He was forthright.

(Testimony of Judge Rodriguez to ACJC, Transcript of ACJC Hearing, dated 

December 16, 2009, Page 89, Lines 10 – 15). 

L. The ACJC Panel Improperly Considers Campbell’s Discrimination 

 Complaint Against Judge Gallipoli

95. During the ACJC hearing on the complaint filed against Campbell a 

member of the ACJC Panel specifically inquired into the status of the discrimination 

complaint that Campbell filed against Judge Gallipoli. Alice Olick (“Olick”) of the ACJC 

panel stated, “I just wonder if counsel could tell us what the status of Judge Campbell’s 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 22 of 34 PageID: 22
23

discrimination complaint against Judge Gallipoli is at the present time.” (Transcript of ACJC 

Hearing, dated December 16, 2009, Page 109, Line 24 – Page 110, Line 2)(emphasis added).

96. After Olick inquired into the status of Campbell’s discrimination complaint, 

Justice Alan Handler, who served as the Chairman of the ACJC panel stated, “Well, if it is 

important, it’s something that the Committee itself could pursue.” (Transcript of ACJC 

Hearing, dated December 16, 2009, Page 110, Lines 8 – 9). 

97. Both Justice Handler and Olick failed to appreciate that Campbell’s 

complaint against Judge Gallipoli had no bearing whatsoever on whether Campbell violated 

judicial canons by engaging in a dating relationship with Kirolos, the type of relationship 

allowed by the Policy on Consensual Dating. It was improper in any manner, shape or form 

for the ACJC Panel to consider the status of Campbell’s complaint against Judge Gallipoli. 

98. The discrimination complaint that Campbell filed against Judge Gallipoli 

was to remain confidential, but its disclosure to the ACJC makes it clear that members of the 

judiciary were making “unofficial” contact with members of the ACJC panel to ensure that 

Campbell would receive a recommendation of punishment as a cover up for the coordinated 

acts of Judge Gallipoli, Moody and Tonelli. 

99. The Supreme Court is charged with oversight of judiciary employees and 

ACJC members. Also, the Supreme Court is charged with enforcing the EEO Policy

Statement, the New Jersey State Constitution, the United States Constitution as well as 

applicable state and federal laws. 

100. Although the Policy on Consensual Dating is contained in the two (2) page 

EEO Policy Statement, it is clear that the Supreme Court took no affirmative actions to train 

the Defendants on the EEO Policy since Judge Gallipoli, the Assignment Judge for Hudson 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 23 of 34 PageID: 23
24

County, Judge Rodriguez, the Chief Judge of the Jersey City Municipal Court, John Tonelli, 

Executive Director of the ACJC, and Candace Moody, Disciplinary Counsel for the ACJC,

were all unaware of the Policy on Consensual Dating which had existed for almost a decade at 

the time Moody filed the complaint against Campbell. 

101. The Supreme Court is also charged with hiring, training, and retaining 

members of the judiciary and the ACJC. The facts herein suggest negligence in this regard.

COUNT ONE

(Equal Protection – Federal Violation)

102. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein. 

103. Campbell has a right to be protected under 42 U.S.C. § 1981 from state action 

that amounts to unequal treatment and adverse action against Campbell based on race. 

104. Campbell has a right to be protected from state action that deprives Campbell 

of his constitutional rights. 

105. The actions of Defendants described above violated Campbell’s right to be free 

from unlawful race discrimination by state action.

106. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under federal law. 

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 24 of 34 PageID: 24
25

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

COUNT TWO

(Civil Conspiracy – Federal Violation)

107. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein. 

108. Plaintiff has a right to be protected under 42 U.S.C. § 1985 from state action 

that amounts to concerted efforts on the part of state agents to subject Plaintiff to unequal 

treatment and adverse action based on Plaintiff’s race. 

109. Campbell has a right to be protected from state action that deprives Campbell 

of his constitutional rights. 

110. The actions of defendants described above violated Campbell’s right to be free 

from unlawful race discrimination and concerted efforts of state actors to conspire against 

Campbell based on race. 

111. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under federal law. 

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 25 of 34 PageID: 25
26

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

COUNT THREE

(Discrimination by Judge Gallipoli – LAD)

112. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein. 

113. Defendant Judge Gallipoli attempted to force Campbell, a black male, to 

resign from his position as a municipal court judge for having a consensual dating relationship 

with Kirolos, a white female.

114. When Campbell chose not to resign Judge Gallipoli aided and abetted by 

Moody sought to punish Campbell through the filing of a baseless ethics complaint.

115. Judge Gallipoli compelled adverse action against Campbell due in part to 

Campbell’s race, sex or marital status. 

116. The actions of Defendants described above violated Campbell’s right to be 

free from unlawful discrimination. 

117. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under the New Jersey Law Against Discrimination

(“LAD”).

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 26 of 34 PageID: 26
27

b) Consequential Damages;

c) Punitive Damages;

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

COUNT FOUR

(Retaliation by Judge Gallipoli – LAD)

118. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein. 

119. Campbell filed a discrimination complaint against Judge Gallipoli in April 

2009. 

120. Judge Gallipoli aided and abetted by another compelled adverse action 

against Campbell in response to the discrimination complaint filed against Judge Gallipoli. 

121. The actions of Defendants described above violated Campbell’s right to be 

free from adverse action for exercising a protected right. 

122. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under the New Jersey Law Against Discrimination.

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 27 of 34 PageID: 27
28

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

COUNT FIVE

(Discrimination by Moody – LAD)

123. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein. 

124. Defendant Moody took adverse action against Campbell due in part to 

Campbell’s race, sex or marital status. 

125. Moody was aided and abetted by another in the adverse action she took 

against Campbell. 

126. The actions of Defendants described above violated Campbell’s right to be 

free from unlawful discrimination. 

127. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under the New Jersey Law Against Discrimination.

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 28 of 34 PageID: 28
29

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

COUNT SIX

(Retaliation by Moody – LAD)

128. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein. 

129. Campbell made a complaint of discrimination against Judge Gallipoli in 

April 2009.

130. Moody aided and abetted by another compelled adverse action against 

Campbell in response to Campbell’s complaint against Judge Gallipoli. 

131. The actions of Defendants described above violated Campbell’s right to be 

free from adverse action for exercising a protected right. 

132. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under the New Jersey Law Against Discrimination. 

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 29 of 34 PageID: 29
30

g) Such other relief as the Court may deem as equitable and just.

COUNT SEVEN

(Unlawful Interference with Prospective Economic Advantage)

133. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein.

134. Defendant Judge Gallipoli aided and abetted by another intentionally 

interfered with Campbell’s prospective economic advantages which included employment and 

business opportunities after Campbell chose not to resign in response to Judge Gallipoli’s 

demands. 

135. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under the New Jersey Law. 

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 30 of 34 PageID: 30
31

COUNT EIGHT

(Abuse of Process by Moody)

136. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein. 

137. Defendant Moody used the ACJC complaint process to punish Campbell 

because Campbell did not submit his resignation upon Judge Gallipoli’s demand. 

138. Moody was aided and abetted by another in the adverse actions she took 

against Campbell.

139. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under the New Jersey Law.

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

COUNT NINE

(Intentional Infliction of Emotional Distress by Defendants)

140. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 31 of 34 PageID: 31
32

141. The Defendants actions described in the preceding paragraphs amounted to 

extreme and outrageous conduct that intentionally or recklessly caused Campbell to suffer 

severe emotional distress.

142. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under the New Jersey Law.

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

COUNT TEN

(False Light in the Public’s Eye caused by Moody)

143. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein.

144. Defendant Moody intentionally sought to damage Campbell’s reputation by 

stating in a formal ethics complaint that Campbell acted in a manner to cause Kirolos to 

overdose, where Moody knew or should have know that these facts were untrue or Moody 

made those allegations in reckless disregard for the truth as stated above. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 32 of 34 PageID: 32
33

145. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under the New Jersey Law.

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

COUNT ELEVEN

(Negligent Investigation)

146. Plaintiff re-alleges and incorporates by reference each and every allegation 

contained in the preceding paragraphs as if set forth fully herein.

147. Defendants Tonelli and Moody failed to thoroughly investigate the matters 

involving Campbell in that they did not interview Campbell or other relevant witnesses prior 

to Moody’s filing of an ethics complaint against Campbell. 

148. Tonelli and Moody failed to research applicable law and relied solely on the 

misrepresentations of Judge Gallipoli who cited no law or policy to support his demands for 

Campbell’s resignation. 

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 33 of 34 PageID: 33
34

149. As a result of Defendants’ unlawful conduct, Campbell has suffered and 

continues to suffer economic losses, emotional distress, bodily injury with physical 

manifestations, physical pain and suffering, harm to his career, harm to his reputation, and 

other such damages compensable under the New Jersey Law. 

WHEREFORE, Plaintiff demands judgment against Defendants for the following:

a) Compensatory Damages;

b) Consequential Damages;

c) Punitive Damages;

d) Attorneys Fees with Enhancement;

e) Costs of Suit;

f) Pre-judgment and Post-Judgment Interest; and

g) Such other relief as the Court may deem as equitable and just.

Respectfully submitted,

 s/ Wilson J. Campbell

By:

Wilson J. Campbell

Plaintiff Pro-Se

Sapphire Village

6320 Estate Smith Bay

St. Thomas, Virgin Islands

Dated: January 31, 2011 wjc@justice.com

DEMAND FOR JURY TRIAL

Plaintiff hereby demands a trial by jury on all issues subject to a jury trial.

Respectfully submitted,

 s/ Wilson J. Campbell

By:

Wilson J. Campbell

Plaintiff Pro-Se

Case 2:11-cv-00555-ES-JAD Document 1 Filed 01/31/11 Page 34 of 34 PageID: 34