NAPOLITANO v. CORBISHLEY

CourtDistrict Court, D. New Jersey
DecidedAugust 9, 2021
Docket2:20-cv-12712
StatusUnknown

This text of NAPOLITANO v. CORBISHLEY (NAPOLITANO v. CORBISHLEY) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
NAPOLITANO v. CORBISHLEY, (D.N.J. 2021).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

ANDREW P. NAPOLITANO, Civil Action No.: 20-12712 (CCC)

Plaintiff, v.

CHARLES CORBISHLEY,

Defendant. _____________________________________

Civil Action No.: 20-15429 (CCC) CHARLES CORBISHLEY,

Plaintiff,

v.

ANDREW P. NAPOLITANO, OPINION Defendant.

FALK, Chief U.S.M.J.

These are two consolidated cases arisin g out of Charles Corbishley’s allegation of

sexual misc onduct against Andrew N apoli t ano and Napolitano’s claim that Corbishley’s

allegatio ns are fabric ated, defamatory, and ext ortionate. Currently before the Court is

Corbishley’s motion to amend his Complaint to add: (1) a claim for defamation; and (2) seven paragraphs of allegations to support the claim (see Proposed Am. Cmpl., ¶¶ 75-82.)

−1− The motion is opposed. No argument is needed. See Fed. R. Civ. P. 78(b). For the reasons stated below, the motion is GRANTED IN PART AND DENIED IN PART.

Specifically, Corbishley will be permitted to amend his Complaint to allege defamation, but the proposed pleading shall not include the allegations set forth at paragraphs 78 and 80-82. RELEVANT BACKGROUND This consolidated action is comprised of two different complaints. In Corbishley v. Napolitano, 20-15429 (CCC), Corbishley claims that he was the victim of sexual

assault while a defendant in a criminal case pending before then-Judge Napolitano in New Jersey Superior Court in 1988. In short, Corbishley claims that his defense attorney, Robert A. Hollis, Esq. (now deceased), was corrupt and arranged for Corbishley to meet with Judge Napolitano at a home in Hackensack, New Jersey, at which Napolitano allegedly demanded sexual favors from Corbishley in exchange for leniency

in his criminal case. In Napolitano v. Corbishely, 20-12712 (CCC), the Complaint contains a single count of defamation, arising out of public comments and statements associated with Corbishley’s Complaint, which is described as an “extortionate scheme and defamatory smear campaign to damage permanently Former Judge Napolitano’s reputation with

fabricated and baseless accusations of sexual misconduct that supposedly occurred more than thirty years in the past.” (Napolitano Compl. (“NC”), ¶ 1.) Napolitano denies

−2− having ever had any private, ex-parte meeting with Corbishley and denied ever having engaged in any sort of sexual contact with him.

In or around December 2019, Corbishley’s lawyers sent Napolitano what he describes as an “extortionate demand letter . . . [and] draft verified complaint asserting false accusations of sexual misconduct and corruption.” (NC ¶ 14.) The parties later engaged in pre-suit mediation which did not result in resolution. On September 11, 2020, Corbishley filed his Complaint in the United States District Court for the Southern District of New York.1 On September 15, 2020, Napolitano filed

his Complaint in this Court. The Current Motion Corbishely seeks leave to amend his Complaint to allege defamation. The proposed amended complaint supporting the motion contains seven paragraphs of allegations under the heading “Defendant Napolitano Manufactures a Completely False

‘Extortion’ Claim against Plaintiff.” (Proposed Am. Compl., p. 11.) Specifically, Corbishley alleges, in part: 75. Apart from making false claims about Corbishley’s threats of violence, Defendant Napoliotano made further false and defamatory statements to the courts, to the media, and to various third-parties, regarding Corbishely.

76. Specifically, Defendant Napolitano told the courts, media, and various third parties that Plaintiff Charles Corbishley had attempted to ‘extort’ money from him

1 On October 21, 2020, Corbishley’s Complaint was transferred to the District of New Jersey by the Honorable Vernon S. Broderick, U.S.D.J. (Civ. A. No. 20-15429; ECF No. 16.)

−3− and had engaged in an ‘extortionate scheme’ prior to instituting this action.

(Proposed Am. Compl., ¶¶ 75-77.)

The Proposed Amended Complaint also contains seven paragraphs (also included in the currently operative complaint) that allege that Napolitano contacted law enforcement and manufactured false claims against Corbishley claiming that he made terroristic threats. (Compl., ¶¶ 64-71.) Corbishley’s proposed amended pleading continues by setting forth additional paragraphs that refer to the parties’ mediation. Corbishley contends that both the pre- existing allegations at paragraphs 64-71 and the new allegations at 75-82 support his proposed defamation claim. Napolitano opposes the motion to amend, claiming: (1) the amendment implicates privileged mediation communications in violation of New Jersey law; and (2) the amendment is futile and fails to state a claim.

LEGAL STANDARDS Rule 15(a)(2) of the Federal Rules of Civil Procedure permits a party to amend its pleading at any point prior to trial “only with the opposing party’s written consent or the court’s leave.” Leave should be freely given by the Court “when justice so requires.” Id. This mandate encompasses a broad range of equitable factors. Arthur v. Maersk,

Inc., 434 F.3d 196, 203 (3d Cir. 2006) (citations omitted). A court will consider whether the delay in seeking amendment is undue, motivated by bad faith, prejudicial, or if it

−4− would ultimately be futile. See, e.g., Foman v. Davis, 371 U.S. 178, 182 (1964). The decision to grant leave rests in the sound discretion of the Court. See Zenith Radio Corp.

v. Hazeltine Research, Inc., 401 U.S. 321, 331 (1971). New Jersey law recognizes that “mediation communications are privileged.” Kernaham v. Home Warranty Adm’r of Fla., Inc., 236 N.J. 301 (2019); see also N.J. R. Evid. 519. A “mediation communication” is defined to include any “statement, whether verbal or nonverbal or in a record, that occurs during a mediation or is made for purposes of considering, conducting, participating in, initiating, continuing, or reconvening a

mediation or retaining a mediator.” N.J.S.A. § 2A:23C-2.2 DECISION Corbishely’s motion to amend will be granted in part and denied in part for the following reasons. Corbishley’s claim is not futile in the context of Rule 15 futility. Futility

generally refers to the concept that the proposed amendment would not survive a Rule 12(b)(6) motion, even assuming everything in the proposed pleading is true. However, although Rule 15 futility closely tracks Rule 12(b)(6), Rule 15 futility does not contemplate substantive motion practice on the merits of the claims. As it has been described:

2 Since this case is here on federal diversity jurisdiction, New Jersey law governs the extent to which the mediation privilege applies in this case. See, e,g., United Coal Companies v. Powell Constr. Co., 839 F.2d 958, 965 (3d Cir. 1988).

−5− If a proposed amendment is not clearly futile, then denial of leave to amend is improper. This does not require the parties to engage in the equivalent of substantive motion practice upon the proposed new claim or defense; [it] does require, however, that the newly asserted defense appear to be sufficiently well- grounded in fact or law that it is not a frivolous pursuit.

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