Lennox S. Hinds, Esq.

STEVENS, HINDS & WHITE, P.C.

42 Van Doren Avenue

Somerset, N.J. 08873

(732) 973-3096

116 West 111th Street

New York, NY 10026

(212)864-4445

Attorney for Plaintiff

______________________________________

KENDRA DENISE BROWN, UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

Plaintiff

Dkt. No. 3:11-CV-02494-MLC-DEA

MIDDLESEX COUNTY, CFG HEALTH AMENDED COMPLAINT AND

SYSTEMS, LLC, WARDEN EDMOND JURY DEMAND

CICCHI, LT. JETTERS, DR. TALBOT,

Defendants.

__________________________

PRELIMINARY STATEMENT

1. This is an action brought by a former officer of the Middlesex County Jail, who 

was brutally mistreated and denied medical treatment at the Jail, in retaliation for 

her whistleblowing and with deliberate indifference to her medical condition, four 

days after she had undergone surgery.

JURISDICTION

2. This action is brought pursuant to 42 U.S. C. §.1983. Jurisdiction to redress

violations of civil rights is provided by 28 U.S.C. § 1343. This Court has 

supplemental jurisdiction over Plaintiff’s State law claims under 28 U.S.C. § 

1367.

Case 3:11-cv-02494-MLC-DEA Document 11 Filed 11/04/11 Page 1 of 7 PageID: 54
VENUE

3. Venue is laid in the District of New Jersey, where Defendants reside and where 

the cause of action arose.

PARTIES

4. Plaintiff, KENDRA DENISE BROWN, is a citizen of the United States and a 

resident of New Jersey.

5. Defendant MIDDLESEX COUNTY is a County government organized under the 

laws of New Jersey. The Middlesex County Jail is operated as a branch of the 

County government.

6. Defendant CFG HEALTH SYSTEMS, LLC, provides health care services for

inmates at the MIDDLESEX COUNTY jail under contract to Defendant 

MIDDLESEX COUNTY. Upon information and belief, Defendant TALBOT 

acted as an employee of Defendant CFG HEALTH SYSTEMS, LLC, and under 

its supervision, and provided and failed to provide medical services in accord with 

its policies and practices. In fulfilling a government function, and in acting 

jointly with the County of Middlesex in the provision of medical services, 

Defendant CFG HEALTH SYSTEMES, LLC acted under color of law.

7. Defendant CICCHI was at all times mentioned herein the warden of the 

Middlesex County Jail, and as such was the chief decision-maker and policymaker with respect to the operations of the Middlesex County Jail. At all times 

mentioned herein, Defendant CICCHI acted pursuant to his authority under the 

Case 3:11-cv-02494-MLC-DEA Document 11 Filed 11/04/11 Page 2 of 7 PageID: 55
laws of New Jersey and of Middlesex County, under color of law.

8. Defendant JETTERS was at all times mentioned herein an officer of the 

Middlesex County Jail, with the rank of Lieutenant. At all times mentioned 

herein, Defendant JETTERS acted pursuant to his authority under the laws of 

New Jersey and of Middlesex County, under color of law.

9. At all times mentioned herein, Defendant TALBOT was the chief medical officer

at the Middlesex County Jail, and had authority to make medical decisions 

concerning detainees at the Middlesex County Jail. Ar all times mentioned 

herein, Defendant TALBOT acted pursuant to his authority under the laws of 

New Jersey and of Middlesex County, under color of law.

AS A FIRST CAUSE OF ACTION

 FACTS

10. On or about May 27th, 2009, Plaintiff had undergone an abdominoplasty surgery

in the Dominican Republic.

11. Upon her return to New Jersey, on or about June 1, 2009, Plaintiff was arrested 

by officers of the Highland Park police department, pursuant to a warrant, on a 

charge of alleged child neglect, and transported to the Middlesex County Jail.

12. Upon information and belief, Defendant CICCHI requested that she be brought to 

the jail with her hands cuffed behind her back and in shackles.

13. Contrary to jail policy when a person being brought to the jail for detention has 

health issues, Plaintiff was accepted into jail custody without having been cleared 

by a hospital, despite the fact that the jail was aware of her medical condition, 

Case 3:11-cv-02494-MLC-DEA Document 11 Filed 11/04/11 Page 3 of 7 PageID: 56
which prevented her being strip-searched in accord with jail protocol.

14. Plaintiff was brought to the medical department of the jail. Defendant 

JETTERS came to the medical department and reported that Defendant 

CICCHI wanted her stripped naked and placed in a paper gown, and ordered her 

stripped and the one abdominal binder she had removed. It is highly unusual for 

the Warden to give orders concerning individual detainees.

15. Plaintiff asked the Director of Nursing why she had not been taken to a hospital. 

The Director of Nursing told Plaintiff that she could not be taken to a hospital 

unless she had a fever.

16. Defendant TALBOT examined Plaintiff, and reduced her medication dosage from 

1000 mgs. of Cipro to 500 mgs. 

17. Plaintiff asked Defendant TALBOT why she was not being brought to the

hospital after having a rough time while being transported to the jail.

18. Defendant TALBOT responded that since she didn’t have a fever, she didn’t need

to go to the hospital, but that if she developed a fever, they would take her to the 

hospital because that meant infection.

19. Plaintiff said “I am going to die in here.” Defendant TALBOT ignored her, and

began to stretch and poke at her belly button.

20. Plaintiff told Defendant TALBOT he was hurting her, and asked who was going 

to clean her wounds, and asked if they had peroxide.

21. Defendant TALBOT told her “we don’t use that here.”

22. Defendant CICCHI caused Plaintiff to be placed in solitary confinement, telling 

his staff not to have any contact with Plaintiff because he falsely claimed she was 

Case 3:11-cv-02494-MLC-DEA Document 11 Filed 11/04/11 Page 4 of 7 PageID: 57
dangerous.

23. Defendant CICCHI also attempted to have Plaintiff deprived of underclothing,

although a female staff member, in disobedience to his order, brought Plaintiff 

underclothing. 

24. Defendant CICCHI deliberately singled Plaintiff out for harsh treatment because,

while working as a correction officer at the jail, she had filed grievances and had 

reported another officer for use of excessive force. 

25. While Plaintiff was in solitary confinement, she had only a one-inch mattress on

a metal bed, which was not appropriate for her given that she had been operated 

on only four days earlier.

26. During the time she was being confined at the jail, and not obtaining medical

treatment, Plaintiff was suffering from a leak of fluids and internal bleeding into 

her abdominal wall, which was not detected at the time because she was not 

brought to the hospital, as was the jail’s standard practice. 

27. Defendant TALBOT, acting with deliberate indifference to Plaintiff’s medical 

conditions, also failed to do a thorough medical examination of Plaintiff to 

determine whether her condition required further assessment or treatment at a 

hospital. 

28. Defendant CFG HEALTH SYSTEMS, LLC failed to adequately supervise the 

delivery of medical treatment at Middlesex County Jail, including the transfer of 

inmates with medical issues to a hospital for assessment before accepting them 

into the jail, causing the failure to treat Plaintiff’s conditions.

29. The deliberate and reckless denial of medical treatment and other intentional

Case 3:11-cv-02494-MLC-DEA Document 11 Filed 11/04/11 Page 5 of 7 PageID: 58
mistreatment of Plaintiff while she was detained at Middlesex County Jail denied 

her rights under the due process clause of the Fourteenth Amendment for which 

Defendants are liable under 42 U.S.C. § 1983.

AS A SECOND CAUSE OF ACTION

30. Plaintiff repeats and realleges ¶¶ 1-29 of this Complaint.

31. Defendants’ denial of Plaintiff’s civil rights subjected them to liability for 

damages pursuant to the New Jersey Civil Rights Act, New Jersey Civil Rights 

Act, N.J.S. 2: 6-2.

AS A THIRD CAUSE OF ACTION 

32. Plaintiff repeats and realleges ¶¶ 1-29 of this Complaint.

33. Defendant TALBOT’s neglect of Plaintiff’s medical conditions and maltreatment 

of Plaintiff grossly departed from the standards of care of the medical profession, 

causing her injuries.

34. Defendant TALBOT and Defendant CFG HEALTH SYSTEMS, LLC are liable 

to Plaintiff for medical malpractice.

Case 3:11-cv-02494-MLC-DEA Document 11 Filed 11/04/11 Page 6 of 7 PageID: 59
Wherefore Plaintiff demands judgment against Defendants in an amount to be 

determined by the trier of fact, for compensatory damages, and, for punitive damages 

against all Defendants legally subject to punitive damages, together with an award of 

reasonable attorney’s fees and costs and such further, other and different relief as this 

Court deems just in the premises.

 /s/__________________

Lennox S. Hinds (LH-8196)

 Attorney for Plaintiff

JURY DEMAND

Plaintiff demands a trial by jury of all issues triable by jury.

 /s/________________

 Lennox S. Hinds (LH-8196)

 Attorney for Plaintiff

Case 3:11-cv-02494-MLC-DEA Document 11 Filed 11/04/11 Page 7 of 7 PageID: 60