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 OCN-L-002447-18 10/09/2018 1:44:46 PM Pg 1 of 7 Trans ID: LCV20181755908

Gregory J. Cannon, Esq.

NJID# 038042007
Sobel Han, LLP
120 Sylvan Avenue, Suite 304
Englewood Cliffs, New Jersey 07632
(201) 603-3697
Attorneys for Plaintiff
Robyn Gedrich

SUPERIOR COURT OF NEW JERSEY

ROBYN GEDRICH,
LAW DIVISION: OCEAN COUNTY
Plaintiff, 2447-18
DOCKET NO.: OCN-L-__________

vs. CIVIL ACTION

DANIEL RODRICK,
COMPLAINT
Defendant.

Plaintiff Robyn Gedrich, by and through her attorneys, Sobel Han, LLP, hereby files this

Complaint for defamation and related claims, alleging as follows:

THE PARTIES

1. Plaintiff Robyn Gedrich (“Plaintiff”) is a resident of Brick Township, New Jersey.

2. Defendant Daniel Rodrick (“Defendant” or “Rodrick”) is a resident of Toms

River, New Jersey.

3. Venue lies in this Court pursuant to N.J. Court Rules 4:3-1 and 4:3-2.

FACTUAL BACKGROUND

Defendant’s Control of Various Websites and Facebook Pages

4. Defendant Rodrick is the owner and operator of several websites that purport to

be political news sites.

5. One of the websites owned by Rodrick is known as the Ocean County Chronicle,

with a domain address of www.oceancountychronicle.com (the “Chronicle Website”).

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6. The Chronicle Website conceals the name of the record owner, but one of

Defendant’s former political allies, Jon Salonis, informed a co-worker that he is personally aware

that the Chronicle Website and several other similar websites are owned and operated by

Defendant.

7. Defendant Rodrick also owns and operates a connection of other political

websites, including the Brick Beacon (www.brickbeacon.com) and Toms River Weekly

(http://trweekly.com).

8. Defendant Rodrick frequently posts the same political news articles on his various

websites.

9. The articles, which typically contain false and misleading facts, are often used by

Defendant Rodrick to promote his own political interests and to undermine his political enemies.

10. Defendant Rodrick also owns and operates a series of Facebook pages that are

used, in part, to direct people to his various websites.

11. The Facebook pages owned and operated by Defendant Rodrick include: (1)

Jackson Watch; (2) Brick Watch; (3) Toms River Watch; and (4) Toms River Taxpayers.

12. Defendant Rodrick also pays Facebook, through the use of fictitious fundraising

committees, to “boost” his website articles and to direct people to his websites.

13. For example, Facebook’s Ad Disclosure Archive discloses that, beginning on

September 29, 2018, a group known as “Citizens for Transparent Government” paid between

$202 and $1198 in Facebook advertising to direct people to Defendant’s Chronical Website.

14. The group “Citizens for Transparent Government” is a fictitious organization that

is owned, operated and funded by Defendant Rodrick.

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15. Defendant Rodrick has set up other fictitious committees to boost his Facebook

pages and has spent between $1,002 and $5,190 (according to Facebook) to direct people to his

various websites.

16. Defendant Rodrick’s expenditures on his political Facebook pages and websites,

without the disclosure of such expenditures in campaign finance reports, constitute clear

violations of campaign finance laws.

17. Defendant Rodrick has intentionally hidden his involvement and control over the

various websites and Facebook pages in order to give them a veneer of credibility and non-

partisan objectivity.

The Defamatory Article

18. On or about October 4, 2018, Defendant Rodrick put up a posting on the

Chronicle Website that is about Plaintiff, and that has the headline “Job Given to Mayor Ducey’s

New Democratic Party Underboss.”

19. The posting also contains a reference to Plaintiff “being hired at the Township of

Brick.”

20. The posting also states: “Opra requests regarding Ms. Gedrich’s new job title and

salary have been submitted to the Township.”

21. The posting also contained a photo of Plaintiff.

22. The statements that Plaintiff has been given a “job” and that she was “hired at the

Township of Brick” are false.

23. The statement that OPRA [Open Public Records Act] requests for Plaintiff’s job

title and salary were submitted to the Township is false.

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24. The posting implies that Plaintiff obtained a public job because of her political

involvement in the Democratic party, which is false and defamatory as it implies corruption and

malfeasance.

25. Plaintiff does not now, and has not ever, had a salaried or paid position with the

Township of Brick.

26. Plaintiff directly informed Defendant Rodrick of the falseness of the allegation in

a telephone conversation on October 4, 2018, the day the posting first appeared.

27. Despite being directly informed by Plaintiff of the false nature of the claim,

Rodrick has failed and refused to remove the posting from the Chronical Website.

28. Defendants is an elected official of the Township of Toms River, but the claims

herein are not alleged against him in his official capacity but solely in his personal capacity.

COUNT I

DEFAMATION

29. The foregoing allegations are incorporated by reference as if fully set forth herein.

30. Defendant Rodrick’s statements about Plaintiff on or about October 4, 2018, in

the posting on the website that he owns and operates, are false and defamatory.

31. Defendant Rodrick’s statements were published to a third party or parties without

privilege.

32. Defendant Rodrick negligently made the false statements.

33. Defendant Rodrick made the statements in reckless disregard of the truth, or with

knowledge of the falsity of the statements.

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 OCN-L-002447-18 10/09/2018 1:44:46 PM Pg 5 of 7 Trans ID: LCV20181755908

WHEREFORE, Plaintiff respectfully demands judgment against Defendant as follows:

A. An award of compensatory damages;

B. An award of punitive damages;

C. Interest, attorneys’ fees, and costs; and

D. Such other and further relief as the court deems just and proper.

COUNT II

FALSE LIGHT

34. The foregoing allegations are incorporated by reference as if fully set forth herein.

35. The statements in the Chronicle Website portray Plaintiff in a false light that

would be highly offensive to a reasonable person.

36. Defendant Rodrick had knowledge of or acted in reckless disregard as to the

falsity of the statements and as to the false light in which Plaintiff would be placed.

WHEREFORE, Plaintiff respectfully demands judgment against Defendant as follows:

A. An award of compensatory damages;

B. An award of punitive damages;

C. Interest, attorneys’ fees, and costs; and

D. Such other and further relief as the court deems just and proper.

SOBEL HAN, LLP

Attorneys for Plaintiff
Robyn Gedrich

By: /s/Gregory J. Cannon – NJID#038042007

Gregory J. Cannon
DATED: October 9, 2018

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 OCN-L-002447-18 10/09/2018 1:44:46 PM Pg 6 of 7 Trans ID: LCV20181755908

DESIGNATION OF TRIAL COUNSEL

Gregory J. Cannon, Esq., is hereby designated as trial counsel on behalf of Plaintiff.

SOBEL HAN, LLP

Attorneys for Plaintiff
Robyn Gedrich

By: /s/Gregory J. Cannon – NJID#038042007

Gregory J. Cannon

DATED: October 9, 2018

CERTIFICATION PURSUANT TO R.4:5-1

I certify that the matter in controversy is not the subject of any other action

pending in any Court, that no other action or arbitration proceeding is contemplated and that no

other parties should be joined in this action.

SOBEL HAN, LLP

Attorneys for Plaintiff
Robyn Gedrich

By: /s/Gregory J. Cannon – NJID#038042007

Gregory J. Cannon

DATED: October 9, 2018

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 OCN-L-002447-18 10/09/2018 1:44:46 PM Pg 7 of 7 Trans ID: LCV20181755908

CERTIFICATION OF SERVICE

I certify that, on this date, I caused to be served, via eCourts, Plaintiff’s Complaint and

CIS upon the Clerk, Law Division, Ocean County Superior Court, 118 Washington Street, Toms

River, New Jersey 08753.

SOBEL HAN, LLP

Attorneys for Plaintiff
Robyn Gedrich

By: /s/Gregory J. Cannon – NJID#038042007

Gregory J. Cannon

DATED: October 9, 2018

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 OCN-L-002447-18 10/09/2018 1:44:46 PM Pg 1 of 1 Trans ID: LCV20181755908

Civil Case Information Statement

Case Details: OCEAN | Civil Part Docket# L-002447-18

Case Caption: GEDRICH ROBYN VS RODRICK DANIEL Case Type: DEFAMATION

Case Initiation Date: 10/09/2018 Document Type: Complaint
Attorney Name: GREGORY JAMES CANNON Jury Demand: NONE
Firm Name: SOBEL HAN LLP Hurricane Sandy related? NO
Address: 120 SYLVAN AVE STE 304 Is this a professional malpractice case? NO
ENGLEWOOD CLIFFS NJ 07632 Related cases pending: NO
Phone: If yes, list docket numbers:
Name of Party: PLAINTIFF : Gedrich, Robyn Do you anticipate adding any parties (arising out of same
Name of Defendant’s Primary Insurance Company transaction or occurrence)? NO
(if known): None

THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE

CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION

Do parties have a current, past, or recurrent relationship? NO

If yes, is that relationship:
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:

Do you or your client need any disability accommodations? NO

If yes, please identify the requested accommodation:

Will an interpreter be needed? NO

If yes, for what language:

I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)

10/09/2018 /s/ GREGORY JAMES CANNON

Dated Signed