MARTINEZ GROCERY II v. UNITED STATES

Filing 18

OPINION. Signed by Judge Noel L. Hillman on 9/27/2019. (dmr)

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

MARTINEZ GROCERY II, et al.
HONORABLE NOEL L. HILLMAN
Plaintiffs,
v.

Civil Action
No. 18-0627 (NLH/KMW)

UNITED STATES OF AMERICA, et
al.
OPINION
Defendants.

APPEARANCES:
Brian E. Turner, Esq.
15 West Park Avenue
Merchantville, New Jersey 08109
Attorney for Plaintiffs
Craig Carpenito, United States Attorney
By: John Tudor Stinson, Jr., Assistant U.S. Attorney
402 East State Street, Room 430
Trenton, New Jersey 08608
Attorneys for Defendants
HILLMAN, District Judge:
I.

INTRODUCTION
This matter comes before the Court by way of a motion for

summary judgment filed by Defendants United States of America
and the Secretary of the United States Department of
Agriculture, Sonny Perdue, (hereinafter, collectively,
“Defendants”) seeking judgment in their favor as to all counts
of the Complaint [Docket Item 1] filed by Plaintiffs Martinez

Grocery II and Juana Martinez (hereinafter, collectively,
“Plaintiffs”).

(See Defs.’ Mot. [Docket Item 13].)

The Court

will grant Defendants’ motion.
II.

BACKROUND 1
A.

The Supplemental Nutrition Assistance Program

This case revolves around the Supplemental Nutrition
Assistance Program (“SNAP”), which is administered by the Food
and Nutrition Service of the United States Department of
Agriculture (“FNS”).

7 U.S.C. §§ 2011–2036.

SNAP provides

assistance to eligible households by supplementing their
available funds to spend on food items.

7 U.S.C. § 2013(a).

Participants use their SNAP benefits to purchase food items at
authorized stores, and the United States then redeems those
benefits by paying the store the full face value of the

1

For purposes of the instant motion and pursuant to Local Civil
Rule 56.1, unless otherwise noted, the Court distills this
undisputed version of events from Defendants’ Statement of
Undisputed Material Facts (“Defs.’ SMF”) [Docket Item 13-1],
Plaintiffs’ Response to Defendants’ Statement of Undisputed
Material Facts (“Pls.’ RSMF”) [Docket Item 14], 1-3, and related
exhibits and documents. The Court presents this version of the
record in the light most favorable to Plaintiffs, as the nonmoving party. The Court will not consider Plaintiffs’
Counterstatement of Undisputed Material Facts (“Pls.’ CSMF”)
[Docket Item 14], 3-4, as it does not comply with the
requirements Local Civil Rule 56.1, most notably because the
vast majority of the document is used to present an excerpt of
the federal regulations and because those few factual statements
included in the document are also included in Defendants’
Statement of Undisputed Material Facts and are responded to in
Plaintiffs’ Response to Defendants’ Statement of Undisputed
Material Facts.
2

benefits.

7 U.S.C. §§ 2013(a), 2016(b), 2018, 2019.

Participation in the program by such stores is managed by FNS
and governed by the relevant statutory and regulatory regime in
order to achieve SNAP’s objectives, while also preventing or
minimizing fraud and abuse.
B.

7 U.S.C. § 2011.

Martinez Grocery II

Martinez Grocery II is a small convenience store that
opened in 1998 in Camden, New Jersey.

Shortly after opening,

Plaintiffs applied to participate in SNAP and were accepted into
the program.

As of June 2017, there were 45 SNAP-participating

retailers within one mile of Martinez Grocery II of varying size
and description.
On May 13, 2017, FNS conducted a site visit to Martinez
Grocery II, which noted that the store did not provide customers
with shopping carts or baskets, only had a single cash register,
and that items for sale exhibited a typical pricing structure,
wherein most prices ended with “x9” cents. 2

2

At the time, the

Plaintiffs attempt to dispute this fact in their RSMF, by
stating that Plaintiffs did not “provide” pricing information to
the FNS reviewer who visited the store. However, the review
form, (A.R. [Docket Item 12], 57), indicates that the reviewer
is supposed to complete the pricing structure question and then
complete the remainder of the form “in collaboration with store
personnel,” which the Court notes does not require Plaintiffs to
“provide” any information to the FNS reviewer, but only
indicates that after the pricing structure is determined, the
remaining questions should be completed in consultation with
store employees. Additionally, Plaintiff contends that certain
items do not fit this typical pricing structure, but neither
3

most expensive items eligible for SNAP were $19.99, $11.99, and
$5.99.
C.

FNS Investigation

In June 2017, FNS began investigating Plaintiffs after
their “Alert System” indicated that Plaintiffs’ recent pattern
of SNAP transactions indicated possible trafficking in SNAP
benefits, 3 in violation of SNAP regulations.

As part of the

Plaintiffs’ RSMF nor the exhibit to which they direct the
Court’s attention, (Aff. of Juana Martinez [Docket Item 14-2]),
indicate whether the indicated non-typical prices were the
prices for these same items on May 13, 2017 or at any other time
relevant to this case. Therefore, Plaintiffs do not here raise
a genuine dispute of material fact.
3

As defined by FNS regulations, trafficking in SNAP benefits
means:
(1)
The
buying,
selling,
stealing,
or
otherwise effecting an exchange of SNAP
benefits issued and accessed via Electronic
Benefit Transfer (EBT) cards, card numbers and
personal identification numbers (PINs), or by
manual voucher and signature, for cash or
consideration other than eligible food, either
directly,
indirectly,
in
complicity
or
collusion with others, or acting alone;
(2) The exchange of firearms, ammunition,
explosives, or controlled substances, as
defined in section 802 of title 21, United
States Code, for SNAP benefits;
(3) Purchasing a product with SNAP benefits
that has a container requiring a return
deposit with the intent of obtaining cash by
discarding the product and returning the
container
for
the
deposit
amount,
intentionally discarding the product, and
4

ensuing investigation, FNS staff collected Plaintiffs’ SNAP
transaction records for the time-period running from December
2016 through May 2017 and analyzed it in conjunction with data
from other nearby SNAP retailers, with the transaction histories
of certain nearby SNAP households, and with established patterns
of SNAP benefit trafficking. 4

intentionally returning the container for the
deposit amount;
(4) Purchasing a product with SNAP benefits
with
the
intent
of
obtaining
cash
or
consideration other than eligible food by
reselling
the
product,
and
subsequently
intentionally reselling the product purchased
with SNAP benefits in exchange for cash or
consideration other than eligible food; or
(5)
Intentionally
purchasing
products
originally purchased with SNAP benefits in
exchange for cash or consideration other than
eligible food.
(6) Attempting to buy, sell, steal, or
otherwise affect an exchange of SNAP benefits
issued and accessed via Electronic Benefit
Transfer (EBT) cards, card numbers and
personal identification numbers (PINs), or by
manual voucher and signatures, for cash or
consideration other than eligible food, either
directly,
indirectly,
in
complicity
or
collusion with others, or acting alone.
7 C.F.R. § 271.2.
4

Plaintiffs attempt to take issue with FNS’s investigation by
asserting that Plaintiffs believe FNS’s “Alert System” may have
been malfunctioning at the time that it flagged Martinez Grocery
II’s transactions for further review, and that the system
flagged the store in error. (Pls.’ RSMF [Docket Item 14], 7 on
the docket; Pls.’ Opp’n [Docket Item 14], 11-12 on the docket.)
5

As a result of the investigation, FNS sent Plaintiffs a
letter on July 27, 2017, charging Plaintiffs with SNAP benefits
trafficking based on three types of suspicious activities
uncovered by FNS’s investigation:
1.

An unusually large number of transactions ending
in $.00 or $.50

2.

Multiple transactions from an individual SNAP
account in a short period of time

3.

Numerous excessively large transactions, relative
to the nature of Martinez Grocery II as a small
convenience store

The July letter indicated that the default sanction for
SNAP trafficking is permanent disqualification from SNAP
participation, but that a retailer could request that FNS
consider a civil monetary penalty instead.
D.

Administrative Proceedings

Plaintiffs requested and were granted numerous extensions
of time to respond to the July 2017 letter.

On August 15, 2017,

Plaintiffs responded to FNS through counsel, asserting that they
had not violated any SNAP regulations.

Specifically, Plaintiffs

alleged that they sell many items that end in $.00 or $.50, that

However, while Plaintiffs take issue with the manner in which
FNS’s investigation was triggered, Plaintiffs do not appear to
challenge the manner in which the investigation was conducted.
Nor do Plaintiffs explain why an allegedly malfunctioning “Alert
System” would invalidate a subsequent investigation, where the
investigation itself was conducted properly. Therefore, the
Court does not consider this dispute to be material to the
outcome of this case.
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all same-household transactions were hours apart, and that
Plaintiffs cannot control a SNAP recipient’s desire to purchase
large amounts of items in a single visit to Martinez Grocery II.
Plaintiffs did not request that FNS consider a civil monetary
penalty in lieu of permanently disqualifying Plaintiffs from
participating in SNAP.

Attached to Plaintiffs’ letter were a

number of additional invoices, allegedly related to Martinez
Grocery II’s inventory.
FNS analyzed Plaintiffs’ response and determined that
[Plaintiffs’] response to [FNS’s] letter of
charges failed to justify or adequately
explain
the
very
suspicious
transaction
activity noted in [FNS’s] charge letter or
demonstrated
by
the
specific
household
shopping activity detailed in [FNS’s] case
analysis. . . . A review of client shopping
data for the review period shows that clients
shopping at Martinez Grocery II are also
shopping at other area grocery stores, as well
as full-line supermarkets and superstores that
offer customers a much larger quantity and
variety of eligible food items.
It is our
conclusion that the firm's transactions more
likely than not represent trafficking.
(A.R. [Docket Item 12], 341.)

Specifically with respect to the

invoices provided by Plaintiffs, FNS determined that
[Plaintiffs’] reply contains invoices from Sun
Wholesale Inc. dated December 1, 2016 through
August 8, 2017 and a summary report of all the
purchases from Sam’s Club dated December 9,
2016 through July 31, 2017. [FNS’s] analysis
revealed that [Plaintiffs] provided invoices
belonging to two different stores owned by the
same retailer: Martinez Grocery II [and a
second, redacted store].

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[. . .]
With regard to the invoices [Plaintiffs]
provided a total of 95 invoices, 56 of which
belong to [REDACTED] (not the subject store)
and 39 invoices belong to Martinez Grocery II.
[. . .]
These invoices and the summary report totaled
$6,659.35 for food items only and including a
40% mark-up of $2,663.74 the total comes to
$9,323.09. The total SNAP redemptions during
the same time period equaled $21,227.84.
Standard 20% per month for cash, credit, and
debit card sales brings Martinez Grocery II’s
total potential sales for the six months to
$7,458.47. . . . The store had a shortage of
$13,769.37 during the six month review period.
It is highly improbable that the store could
support the SNAP redemptions based on its
invoices.
(Id. at 339-40.)
Therefore, FNS determined that Plaintiffs had not
sufficiently responded to the allegations in FNS’s July letter
and FNS issued a decision letter on September 19, 2017
concluding that Plaintiffs had engaged in SNAP trafficking and
permanently disqualifying them from participation in SNAP
Plaintiffs officially appealed FNS’s decision letter on
October 2, 2017 and submitted additional materials for review on
October 31, 2017.

FNS determined that these additional

materials did not contain any new arguments or any new evidence
in relation to the trafficking allegations.

FNS also noted that

the number of suspicious SNAP transactions at Martinez Grocery

8

II “dropped to zero” in the month after FNS gave Plaintiffs
notice of the suspected trafficking.
On December 11, 2017, FNS issued its Final Agency Decision
regarding Plaintiffs’ appeal, concluding that
[FNS] determined that [Plaintiffs] likely
trafficked in SNAP benefits. The charges of
violations were based on [FNS’s] assessment
that substantial evidence exists that the
questionable transactions occurring during
the
review
period
displayed
patterns
inconsistent with legitimate sales of eligible
food to SNAP participants. The evidence [FNS]
considered in support of its determination
included:
• The irregular SNAP transaction data of
[Plaintiffs] as compared to similar
stores;
• Observations made during an store visit
by a USDA contractor, including the
inadequacy of the firm's staple food
stock to support such large transactions;
• The availability of other SNAPauthorized
stores
located
close
to
[Plaintiffs]; and,
• Shopping behaviors of [Plaintiffs’]
customers.
The transaction data and overall firm record
demonstrate
the
patterns
of
unusual,
irregular, and inexplicable SNAP activity for
this firm is likely the result of trafficking.
Upon review, [Plaintiffs] failed to prove by
a preponderance of the evidence that the
administrative action should be reversed.
[Plaintiffs] provided inadequate explanations
for
the
suspicious
transactions
and
insufficient
evidence
to
legitimize
its
transaction data.
It has not convincingly
rebutted
the
[FNS’s]
determination
that
[Plaintiffs] most likely trafficked in SNAP
benefits. The SNAP regulations are specific
with regard to the action that must be taken

9

if personnel of the firm have trafficked,
which is that FNS must disqualify the firm
permanently.
(A.R. [Docket Item 12], 552.)
On January 16, 2018, Plaintiffs filed the present case,
seeking to overturn FNS’s Final Agency Decision.
III. STANDARD OF REVIEW
Pursuant to Fed. R. Civ. P. 56(c), a motion for summary
judgment will be granted if the pleadings, depositions, answers
to interrogatories, and admissions on file, together with the
affidavits, if any, show that there is no genuine dispute as to
any material fact and that the moving party is entitled to
judgment as a matter of law.

See Anderson v. Liberty Lobby,

Inc., 477 U.S. 242, 247 (1986); Celotex Corp. v. Catrett, 477
U.S. 317, 322 (1986).

“[S]ummary judgment may be granted only

if there exists no genuine issue of material fact that would
permit a reasonable jury to find for the nonmoving party.”
Miller v. Ind. Hosp., 843 F.2d 139, 143 (3d Cir. 1988).

All

facts and inferences must be construed in the light most
favorable to the non-moving party.

Peters v. Del. River Port

Auth., 16 F.3d 1346, 1349 (3d Cir. 1994).
In deciding a motion for summary judgment, the court’s role
is not to evaluate the evidence and decide the truth of the
matter, but to determine whether there is a genuine issue for
trial.

Anderson, 477 U.S. at 249.

10

Credibility determinations

are the province of the factfinder, and thus at the summary
judgment stage credibility issues should be resolved against the
moving party.

Big Apple BMW v, Inc. v. BMW of N. Am., Inc., 974

F.2d 1358, 1363 (3d Cir. 1992); Meyer v. Riegel Prods. Corp.,
720 F.2d 303, 307 n.2 (3d Cir. 1983).

However, “[t]he mere

existence of a scintilla of evidence,” without more, will not
give rise to a genuine dispute for trial.
252.

Anderson, 477 U.S. at

In the face of such evidence, summary judgment is still

appropriate “[w]here the record ... could not lead a rational
trier of fact to find for the nonmoving party.”

Matsushita

Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587
(1986).
IV.

DISCUSSION
Plaintiffs’ Complaint alleges two claims.

[Docket Item 1].)

(See Complaint

Count One seeks trial de novo regarding

Defendants’ finding that Plaintiffs engaged in trafficking.
(See id. at ¶¶ 30-36.)

Count Two seeks a finding that

Defendants’ decision to permanently disqualify Martinez Grocery
II from the SNAP program was arbitrary and capricious.

(See id.

at ¶¶ 37-40.)
A.

Legal Standard

The SNAP program provides for judicial review of any final
determination by the FNS for aggrieved parties.
§ 2023(a)(13).

7 U.S.C.

The statute states that “the suit ... shall be a

11

trial de novo by the court in which the court shall determine
the validity of the questioned administrative action in
issue....”

7 U.S.C. § 2023(a)(15).

analysis in such cases.
a violation occurred.

Courts apply a two-step

“First, the [c]ourt must review whether
For this inquiry, the plaintiff

challenging the administrative action has the burden of proving
by a preponderance of the evidence that the charged SNAP
violation did not occur.”

White Horse No. 2 v. United States,

No. 11-1538, 2012 WL 1533468, at *2–3 (D.N.J. Apr. 30, 2012)
(citing Han v. Food and Nutrition Service, 580 F.Supp. 1564,
1567 (D.N.J.1984) (“plaintiff bears the burden of establishing
by a preponderance of the evidence that the agency’s
determination to disqualify [plaintiff] from participating in
the Food Stamp Program is factually incorrect.”)).
Regarding a plaintiff’s right to trial de novo, the Third
Circuit has held that “de novo review is compatible with a
summary judgment disposition if there are no material facts in
dispute.”

Freedman v. U.S. Dep’t of Agric., 926 F.2d 252, 261

(3d Cir. 1991) (citing In Suk Pak v. U.S. Dep’t of Agric., 690
F. Supp. 322 (M.D. Pa. 1987), aff’d, 853 F.2d 918 (3d Cir.
1988); Modica v. United States, 518 F.2d 374, 376 (5th Cir.
1975) (“[d]espite the trial de novo provision, it is clear that
summary judgment is a proper means of disposing of requests ...
where there are presented no genuine issues of material fact”)).

12

If a plaintiff fails to meet its burden to show that there
was no violation of the SNAP program, the court then turns to
step two: determining whether the sanction imposed by FNS is
appropriate.

“The standard of review for the imposition of a

sanction under SNAP is whether the Secretary’s action was
arbitrary or capricious, i.e., whether it was ‘unwarranted in
law or without justification in fact.’” Atl. Deli & Grocery v.
United States, No. 10-4363, 2011 WL 2038758, at *5 (D.N.J. May
23, 2011) (quoting Willy’s Grocery v. United States, 656 F.2d
24, 26 (2d Cir. 1981)).

Therefore, the plaintiff “has the

burden of introducing evidence into the record that would allow
the Court to conclude that the agency’s determination ... is
unwarranted in law or fact.”
B.

Id.

Step One: SNAP Violation

As explained, supra, the Third Circuit has determined that
the statutory requirement of a trial de novo can be satisfied
through a motion for summary judgment, where there are no
material facts in dispute.
Modica, 518 F.2d at 376.

Freedman, 926 F.2d at 261; see also
While Plaintiffs have attempted to

raise disputes of facts relating to the “Alert System” and the
pricing structure employed by Martinez Grocery II, none of these
disputes are material to the Court’s current analysis, because
Plaintiffs have failed to establish why the functioning of the
“Alert System” would call into question the results of the

13

ensuing investigation, nor have Plaintiffs alleged, much less
established, that the evidence relating to a “$.00” and “$.50”
pricing structure represents prices for items as they appeared
at the time of the FNS site visit or during the six-month period
investigated by FNS.

(See, supra, Notes 2 and 3.)

Therefore,

the Court turns to step one of its analysis.
As also explained, supra, it is Plaintiffs’ burden at step
one to prove, by a preponderance of the evidence, that FNS’s
decision to permanently disqualify Plaintiffs from further
participation in SNAP was incorrect.

Plaintiffs assert that

summary judgment is premature at this stage, because they seek
greater discovery related to the “Alert System” and because
Plaintiffs assert that the evidence relating to a “$.00” and
“$.50” pricing structure creates a genuine dispute of material
fact.

(See Pls.’ Opp’n [Docket Item 14], 10-13 on the docket.)

Regarding the “Alert System,” Plaintiffs argue “the proper
functioning of the [“Alert System”] is necessary to the FNS
upholding” Plaintiffs’ disqualification.
docket.)

(Id. at 11 on the

Plaintiffs do not provide citation to any legal

authority to support this proposition.

(See id.)

Nor do

Plaintiffs explain why this must logically flow from existing
legal authorities.

(See id.)

Rather, Plaintiffs assert that

the results of FNS’s investigation must be entirely invalidated
because Plaintiffs believe they should not have been

14

investigated in the first place.

Plaintiffs do not allege that

the investigation was triggered for a nefarious or improper
reason, but only baldly allege that the “Alert System” is not
trustworthy.

(See id.)

However, Plaintiffs do not explain, nor

do Plaintiffs provide any legal authority to explain, why the
trustworthiness of the “Alert System” is relevant to the
validity of the subsequent investigation, where the procedures
and methods of that subsequent investigation are not being
challenged.

(See generally id.)

FNS’s decision to disqualify

Plaintiffs from further participation in SNAP was not based on
the “Alert System” but rather on the fruits of the ensuing
investigation, which showed — independently of the “Alert
System” — that Plaintiffs engaged in numerous activities
consistent with SNAP trafficking.
With regard to Plaintiffs’ evidence regarding Martinez
Grocery II’s pricing structure, the Court has already explained,
supra, why this does not create a genuine issue of material
fact.

The photos do not establish that these were the prices of

these items at any time that is relevant to this case, nor do
the photos provide support for the proposition that the store
generally has a “$.00” or “$.50” pricing structure.

They are

photos of a small number of items with such a pricing structure
taken at an entirely unknown date.
issue of material fact in this case.

That cannot create a genuine

15

Plaintiffs do not claim

that they need additional time for discovery on this issue, nor
could they, since information about Plaintiffs’ pricing
structure is within Plaintiffs’ own control and any additional
information could have been submitted in the briefing related to
this motion.
Therefore, the Court finds that Plaintiffs have failed to
make any argument that FNS’s determination was incorrect, much
less to carry their burden of proving such by a preponderance of
the evidence.
C.

Step Two: Arbitrary or Capricious Sanction

The Court next turns to step two, which requires the Court to
determine whether the sanction imposed by FNS was arbitrary or
capricious. Plaintiffs have the burden to show that FNS’s decision
to

ban

them

from

SNAP

was

“‘unwarranted

in

law

or

without

justification in fact.’” Atl. Deli & Grocery, 2011 WL 2038758, at
*5 (quoting Willy’s Grocery, 656 F.2d at 26).
Plaintiffs’ brief does not provide any argument to support
their burden with respect to step two.

(See generally Pls.’ Opp’n

[Docket Item 12], 10-13 on the docket.)

Plaintiffs’ complaint

alleges that FNS’s sanction was arbitrary and capricious because
FNS’s

charge

and

determination

letters

did

not

specifically

indicate that FNS’s decision was guided by the enumerated bases
for such a determination as set forth at 7 C.F.R. § 278.6(d):

16

1. The nature and scope of the violations
committed by personnel of the firm,
2. Any prior action taken by FNS to warn the
firm about the possibility that violations
are occurring, and
3. Any other evidence that shows the firm’s
intent to violate the regulations.
(See Complaint [Docket Item 1], ¶ 38.)
However, FNS’s charge letter clearly states that Martinez
Grocery II has been charged with SNAP trafficking and that the
mandatory sanction if such a violation is found to have occurred
is disqualification from SNAP, unless Martinez Grocery II
requested that FNS consider a civil monetary penalty.

It is

undisputed that Plaintiffs never made such a request.

Unlike

with other violations of SNAP rules and regulations, 7 C.F.R.
§ 278.6(e)(1) “mandates automatic disqualification for any
trafficking offense.”

Grocery Town Mkt., Inc. v. United States,

848 F.2d 392, 393 (3d Cir. 1988).

Therefore, FNS is not

permitted to consider any mitigating circumstances, including
the considerations in 7 C.F.R. § 278.6(d).
Plaintiffs further allege in their complaint that FNS’s
letters were so ambiguous that Plaintiffs were unable to
effectively respond to the letters and were unaware of how FNS
considered Plaintiffs’ responses to such letters.
Complaint [Docket Item 1], ¶ 39-40.)

(See

However, Plaintiffs have

not specifically alleged now FNS’s letters were deficient or
what further information would have been necessary for them to

17

mount an effective defense to the allegations, nor have
Plaintiffs taken the opportunity to explain any of these issues
more fully in the briefing responding to the present motion.
FNS’s initial charge letter includes attached forms listing
each of the suspicious transactions that FNS identified.
A.R. [Docket Item 12], 178-188.)

(See

Then ultimately FNS issued a

10-page Final Agency Decision explaining the basis for upholding
its initial decision, which took into account the information
collected by FNS during its investigation as well as the
responses and attached documents submitted by Plaintiffs.
id. at 544-553.)

(See

Plaintiffs have never specified what

information was missing from these documents in order for
Plaintiffs to “effectively refute” the allegations against them.
Nor did Plaintiffs take the opportunity to more fully explain
these issues in response to the pending motion.
Therefore, Plaintiffs have failed to meet their burden to
show that FNS’s actions were arbitrary or capricious.
Furthermore, Plaintiffs have not even claimed that further
discovery would be of assistance in meeting their burden.

As

such, Defendants’ motion for summary judgment shall be granted
in full.

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V. CONCLUSION
For the reasons set forth above, Defendants’ motion for
summary judgment [Docket Item 13] will be granted.

An appropriate

Order follows.

September 27, 2019
Date

s/ Noel L. Hillman
NOEL L. HILLMAN
United States District Judge

At Camden, New Jersey

19