MANCHESTER, NJ — A tenant at Surf and Stream Campground in Manchester has filed a lawsuit against Ocean County and the campground’s owner, seeking to temporarily halt eviction proceedings and to force the two entities to help the residents find new homes.

The lawsuit, filed Tuesday, says the owners of Surf and Stream Campground and Ocean County officials are leaving the residents — 160 people live there permanently — to fend for themselves, despite laws that require government agencies to provide help.

Riverside at Manchester LLC, which owns Surf and Stream Campground, reached an agreement with Ocean County officials and Manchester Township in January for the county and Manchester to purchase the 20.10-acre property for $7.45 million and preserve it as open space. The plan is to turn it into a passive recreation park along the Union Creek branch of the Toms River.

Manchester is contributing $1.5 million, while Ocean County is paying the remaining $5.95 million, under the agreement.

Manchester Mayor Robert Hudak said the purchase removes the possibility of a development of about 245 homes that had been discussed before the agreement with the county, which Manchester approved in late December 2021.

To close on the sale, however, the 160 people living at Surf and Stream Campground must move. Eviction notices have been sent to at least 20 residents, with court dates at the end of June.

Barry Bielat, the owner of Riverside at Manchester, on Wednesday said the eviction notices were sent because the permanent residents had not paid rent in months, saying many had taken advantage of the coronavirus pandemic to stop paying their fees.

Bielat said the campground is owed more than $600,000 in back rent from the tenants.

Marie Cicalo, the tenant who filed the lawsuit on behalf of herself and the other permanent residents, said Bielat’s claim about the back rent is not true.

Cicalo, who worked in the campground’s office in addition to being a tenant, said that with a handful of exceptions, everyone had been paying their rent until February, when the campground stopped accepting rent payments.

“I ran this place for the last three-and-a-half to four years, so I was privy to all people’s accounts,” Cicalo said.

Cicalo said the first notification the tenants had was when news reports about the county’s land purchase were published in January.

There were some people who hadn’t paid rent for years, and there are some “bad apples,” but she said nothing was done about collecting the back rent or addressing issues that resulted in multiple calls to the police department, she said.

Bielat’s attorney, Christopher Dasti, told Jersey Shore Online that the residents aren’t being evicted solely over nonpayment of rentbut for other violations at the site, and that they had been warned the site was shutting down May 23.

The people living at the campground include veterans with PTSD, single parents left financially in distress after divorce, senior citizens, and people with disabilities whose incomes are too low to afford rent in the apartments in the area, Cicalo said.

Rent at the campground is $650 per month, well below the going rate for one-bedroom apartments in Ocean County.

“Many of the tenants have emotional, physical and mental disabilities and are unable to plan for a move or other housing without assistance and guidance,” the lawsuit says.

Kevin Starkey and Terrance Turnbach, the attorneys representing Cicalo and the other tenants, said that under the law, Riverside and Ocean County must provide assistance to the people being forced out of their homes.

“The relocation assistance is an obligation of the county,” Starkey said. “When the government is removing people from their homes or removing businesses, it must provide the assistance.”

The Relocation Assistance Act provides for a number of measures, including rental assistance and funds for moving expenses. It requires a plan to be drawn up and approved by the state Department of Community Affairs to ensure those being displaced from a property are able to find “comparable decent, safe and sanitary housing” elsewhere.

Ocean County officials declined to comment on the lawsuit.

At the direction of Ocean County Counsel, because the matter is now in litigation, there will be no comment from the County,” said Donna Flynn, spokeswoman for the county.

Starkey said Manchester Township was not named in the lawsuit because the obligation to help the tenants belongs to the county, not the town.

Bielat said he offered the names of campgrounds where the permanent residents could move. He declined to say which campgrounds and would only say one was in Ocean County and another was in South Jersey.

Cicalo said the tenants never received any information on other campgrounds, and says Bielat has engaged in a campaign to bully the residents out, by shutting off the hot water to the public bathroom and its showers, which were the only shower access for some residents, shutting down laundry facilities and by halting trash pickup, which has resulted in garbage piling up around the campground, creating a health hazard.

The Ocean County Health Department visited the site, but Daniel Regenye, public health coordinator for the county, said the review is ongoing.

“Once this review is complete and the report is finalized, it can be made available,” he said.

Cicalo said the tenants simply need more time and help in trying to find other places to live that they can afford — a significant challenge in the current housing market. The average rent for a one-bedroom apartment in Manchester is more than $1,500 per month — more than double the rents paid at the campground. The wait for affordable housing lists is months-long.

The lawsuit is seeking a 90-day stay in the eviction procedure to give them adequate time to find other housing, in addition to forcing the creation of a plan to help the residents find housing.

“There’s no way 60 days is enough in this housing market,” Cicalo said.

“Most of the people in here are just hardworking people,” Cicalo said. “They go to work every day and try to live within their means and keep a roof over their heads. They’re retired, they’re living on disability.”

“There are a few bad apples,” she said, referring to comments made by Hudak referencing police calls to the campground. But most of the residents are just trying to get by and live their lives.

There are families with children who attend Manchester schools living there — about 20 of the 160 permanent residents are children, she said.

Attempts to get help from the county so far have been futile, Cicalo said. She was present when one man, a single father with a 9-year-old daughter, sought help from the county’s Social Services office. They told him he would have to be living in his car with his daughter to get help.

“Why put her (the 9-year-old child) through that kind of trauma?” she said.

Cicalo said the goal of the tenants is not to stay forever. They recognize Bielat’s right to sell the property. They just need time and real help for those who aren’t able to navigate the system alone.

“They can sell the place, that’s their right. We didn’t ask to stay here forever,” she said.

Cicalo said that she intends to fight to see the tenants, some of whom have lived there for decades, get the help they are entitled to receive.

“I could have left, but these people need help. I’m going to stay to the end,” she said.