Public Record Notice (Template)
PUBLIC RECORD NOTICE
The documents contained on this page, including but not limited to affidavits, rebuttals, tort claim notices, and related submissions concerning the Glen Ridge Police Department and public officers, are intended to serve as a public record.
These documents have been made publicly accessible in accordance with principles of:
-
Transparency and accountability in government operations;
-
Public Rights Doctrine and Popular Sovereignty, recognizing the people as the ultimate authority;
-
New Jersey Open Public Records Act (OPRA), N.J.S.A. 47:1A-1 et seq., supporting access to governmental records;
-
U.S. Freedom of Information Act (FOIA), 5 U.S.C. §552, supporting public disclosure of information concerning government conduct;
Purpose:
-
To preserve a legal and historical record of official actions, including investigations, internal affairs reports, and civil rights concerns;
-
To provide public access for review, transparency, and accountability;
-
To document the timeline and content of government actions for potential legal reference.
Usage:
-
The contents may be freely accessed, downloaded, and referenced for educational, journalistic, civic, or legal purposes.
-
Users must not modify the original documents.
Disclaimer:
-
Personal information unrelated to public officers or government action has been redacted where necessary to protect privacy.
-
This notice is not intended to replace any legal filings or proceedings; it supplements legal documentation by providing public access.
Date of Record Creation: September 4, 2025
Author / Beneficial Owner: Naomi Johnson, We The People / Private Woman
____________________________________________________
UNITED STATES DISTRICT COURT
FOR THE [Insert District] DISTRICT OF [Insert State]
Naomi Johnson,
Plaintiff,
v.
Sergeant Anthony Maza
The Honorable Judge Mark Clemente
Elizabeth Brewster, Esq.
Denise C. Iandolo Administrator,
Violations Clerk
Defendant.
Civil Action No.:
_________________________________
COMPLAINT FOR VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983
I. JURISDICTION
This Court has jurisdiction under 28 U.S.C. § 1331 and 28 U.S.C. § 1343 because this action arises under the Constitution and laws of the United States, including 42 U.S.C. § 1983.
II. PARTIES
Plaintiff:
[Your full name]
[Your mailing address]
[City, State, ZIP]
[Phone Number or Email, if available]
Defendant(s):
[Name of government official(s)]
[Job title and department, e.g., Officer of [City] Police Department]
[Address if known or “Address Unknown”]
III. STATEMENT OF FACTS
1. On or about [date], at approximately [time], the Defendant(s) [describe what happened—who, what, when, where].
2. The events occurred at [location].
3. The Defendant(s), acting under color of state law, [describe what they did or failed to do].
4. As a result of these actions, the Plaintiff suffered [describe the harm or injury, physical, emotional, legal, etc.]. Leave out emotion and opinionated action
FACTUAL ALLEGATIONS
I. February 24, 2025 – The Unlawful Stop and Seizure of Naomi Johnson’s Conveyance
1. On Monday, February 24, 2025, in Glend Ridge, NJ, Naomi Johnson was stopped by Sergeant Anthony D. Mazza of the Glen Ridge Police Department while traveling privately in her personal conveyance around 3pm.
2. Ms. Johnson immediately requested Sgt. Mazza’s badge number, to which he responded that it was Badge 86 and confirmed his rank as Sergeant.
3. Sgt. Mazza alleged that Ms. Johnson failed to stop at a stop sign, a claim Ms. Johnson disputed, explaining that she briefly stopped and proceeded safely.
4. When questioned further by Ms. Johnson, Sgt. Mazza stated that he pulled her over under "probable cause," but he did not articulate any suspicion of a crime.
5. Ms. Johnson asked Sgt. Mazza what was the articulable suspicion he had to initiate the stop, and he appeared surprised by her legal understanding.
6. Sgt. Mazza then claimed he would have Ms. Johnson’s conveyance towed for being “unregistered.”
7. Ms. Johnson did not consent to the seizure or towing of her vehicle and was not presented with a judicial warrant authorizing such action.
8. Maza did not offer to provide any accommodation after he towed Naomi conveyance that displayed a handicap symbol on her license plate. She was left to walking home as a disable woman.
9. After the incident, Ms. Johnson called the Glen Ridge Police Department to report the unlawful seizure. Her call was referred to Internal Affairs, and later that day, Officer Daniel Manley contacted her.
10. Officer Manley engaged Ms. Johnson in a phone conversation during which she explained the events in detail, including her position that probable cause and articulable suspicion both require a connection to a criminal offense.
11. Officer Manley confirmed that probable cause is a higher standard than articulable suspicion, but he did not dispute that neither standard was appropriately met.
12. When Ms. Johnson asserted that traveling does not require a driver’s license or vehicle registration for non-commercial activity, Officer Manley acknowledged he had heard of that interpretation but deferred the issue to the federal courts.
13. Officer Manley advised Ms. Johnson to re-register her vehicle before attempting to retrieve it, despite her assertion that it was already registered and that her online payment had been processed in September 2024.
II. Attempts to Recover Property and Evidence of Predatory Towing
13. On March 1, 2025, Ms. Johnson and her neighbor visited the New Jersey Motor Vehicle Commission (MVC) in Newark to verify registration status.
14. MVC agents advised Ms. Johnson to pay again in person and request a reimbursement, acknowledging there may have been a system error. She was also told to call MVC’s investigation department for a deeper inquiry.
15. That same day, Ms. Johnson visited E.C.R.B. Towing & Recovery at 329 Broad Street Rear, Bloomfield, NJ, but the facility was closed, despite their business card advertising 24-hour operation.
16. Ms. Johnson’s friend spoke with an E.C.R.B. employee who confirmed weekend storage fees would apply even if they were closed, an arrangement Ms. Johnson contends is unfair and predatory.
17. On March 3, 2025, Ms. Johnson returned to Glen Ridge Police Department to present proof of registration, and subsequently returned to the towing company to retrieve her vehicle.
18. Upon arrival, Ms. Johnson was quoted a total of $575.69 for towing and storage. She objected to the excessive fee and explained she was on a fixed disability income.
19. Ms. Johnson had previously called the tow company on February 26 and February 27, and was quoted approximately $300, confirming that the fee had substantially increased due to the delay caused by their closure.
20. Bob, the E.C.R.B. employee, itemized the charges: $280 storage, $95 hook fee, $85 yard fee, $75 towing notification, $22.14 credit card fee, and tax. He also admitted they initiated title procedures for abandonment, despite Ms. Johnson’s attempts to recover her property.
21. E.C.R.B. Towing & Recovery charged Naomi an "abandonment notice" fee to initiate a title transfer of her private automobile before the lawful time frame of 15–30 days under New Jersey law. This was an unlawful attempt to convert her property before due process could be afforded.
22. Naomi attempted to retrieve her vehicle from E.C.R.B. Towing on three separate occasions but was unable to do so because the business was closed, despite the company advertising “24 Hour Service” on its business card. The misleading advertisement led Naomi to believe the lot would be accessible for vehicle retrieval during all hours. However, it was only available for towing dispatch—not vehicle pickup. Her attempts were as follows:
• February 26, 2025, at 4:30 PM – Closed
• February 27, 2025, at 4:30 PM – Closed
• March 1, 2025, at 12:00 PM – Closed; no accommodations made for retrieval
23. Naomi read nnder New Jersey law and consumer protection regulations, a towing company is required to maintain an office open from 8:00 AM to 6:00 PM at least five days per week and provide reasonable access for after-hours vehicle release. E.C.R.B. failed to comply with these standards, causing Naomi further hardship.
In formal notices and certified correspondence sent to the Glen Ridge Police Department, the Municipal Court, the towing company, Prosecutor Elizabeth Brewster, and Administrative Court Clerk Denise C. Iandolo, Naomi cited Glen Ridge Borough Ordinance Chapter 10-05 (Impound of Vehicles), which states that a vehicle may only be towed if it is:
• Abandoned
• Disabled
• Illegally parked
• Involved in a motor vehicle crash
• Stolen and recovered
• Suspected or identified as being involved in a criminal act
Naomi documented the above codes in her document to show that the court had no jurisdiction.
25. Naomi emphasized that her vehicle did not fall under any of the above categories and cited violations of the New Jersey Predatory Towing Prevention Act, reinforcing that the seizure of her property was unlawful.
26. Naomi certified and mailed a Writ of Replevin to reclaim her private conveyance before paying any excessive and unlawful fees to Chief Quinn but he did not respond to the writ.
27. Naomi submitted a Notice of Default and Demand for Dismissal to Glen Ridge Municipal Court after her Motion to Dismiss and Notice to Show Cause were ignored. She included a written response to Prosecutor Elizabeth Brewster, with a courtesy copy to Judge Mark Clemente, citing violations of judicial duty, failure to establish jurisdiction, and denial of due process and equal protection under the law.
28. Naomi followed up with a certified Notice of Claim and Claim of Damages for Unlawful Summons, addressed to Borough Risk Management Officer and Administrator Michael Zichelli on April 17, 2025. As of the filing of this Complaint, she has received no response.
29. Naomi also sent a certified demand letter to Joe Strollo, owner of E.C.R.B. Towing & Recovery, demanding the return of her automobile and citing violations of the Predatory Towing Prevention Act and Glen Ridge Borough towing ordinances. She additionally hand-delivered a copy of the letter to towing employee Bob, who promised to pass it to the office manager, Lynda Credico.
30. Naomi was later told that the police department was responsible for authorizing the tow and that any financial reimbursement or complaint resolution would need to be directed toward the Glen Ridge Police Department. Despite repeated efforts, Naomi has not been reimbursed or compensated by either party.
31. Naomi contacted Glen Ridge Borough Administrator Michael Rohal to request public records and documentation regarding Sergeant Mazza’s conduct and personnel file. Mr. Rohal responded via email, stating that her Open Public Records Act (OPRA) request was denied.
32. Naomi sent another certified Notice of Claim and Claim of Damages for Unlawful Summons to Michael Zichelli. Again, no response was received, demonstrating a consistent refusal by municipal officials to address the violations.
33. Naomi has also reported this matter and the broader pattern of violations to multiple oversight and government agencies, including:
• Essex County Risk Management Office
• New Jersey Attorney General’s Office of Civil Rights
• Washington Civil Rights Division
• New Jersey Division of Consumer Affairs
• Secretary of State
• Federal Trade Commission (FTC)
• Consumer Financial Protection Bureau (CFPB)
• Washington Disability Rights Section
Out of eight of the above business only two responded. The New Jersey Attorney General’s Office of Civil Rights respond to me via email and said they do not have enough staff to take on the. However the suggest Naomi to reach out to a Civil Right Attorneys. Federal Trade Commission (FTC) said that they do not handled cases like Naomi.
35. Naomi stated clearly in her legal correspondence that she believes Sergeant Mazza and the Glen Ridge Police Department committed a misapplication of statute and municipal code, violating her constitutionally protected rights, her due process protections, and federal disability access laws under Title II of the ADA.
23. Officer Dan Manely of Glen Ridge Police Department contacted Naomi Johnson by telephone and stated, "You misunderstood our conversation. May you call me back? I know you have to go to court and I will see what the outcome is to determine what act to take against Maza." Naomi did not return his call, as she believed he was attempting to cover for his fellow officer and was honoring the "blue wall of silence" rather than objectively investigating the misconduct complaint against Sergeant Anthony Mazza.
24. Ms. Johnson asserted that the towing was unlawful, lacked judicial authorization, and amounted to theft. She served a True Bill to the employee and demanded to speak with the owner, but no manager ever returned her call.
25. Ms. Johnson recorded the entire interaction, including her service of legal notice, and took photos of spoiled food left in her car during the seven-day impoundment.
26. As a result of the fee, Ms. Johnson lacked funds to purchase groceries and was forced to go without food until her next disability check or access to a food pantry.
27. She used her credit card to pay the impound fee and took several months to pay off the balance, incurring financial hardship.
III. Impact on Ms. Johnson’s Health, Safety, and Psychological Well-Being
25. Following the incident, Ms. Johnson feared further targeting by Sgt. Mazza and began altering her travel routes. Her therapist had to coach her into leaving her home due to heightened anxiety.
26. Ms. Johnson began conducting therapy by video and avoided traveling past Glen Ridge altogether.
27. She reported the incident to a police friend in Newark, Officer Jay, who confirmed that failing to renew a vehicle registration is distinct from operating an unregistered vehicle.
28. Officer Jay stated that he typically advises drivers to renew online and does not tow for expired registrations, further confirming that Sgt. Mazza’s actions were excessive and unsupported. Jay suggested that Maza perhaps put the unregistered vehicle to solidify the reason of the towing because an unregistered vehicle is a higher point.
IV. OPRA Requests and Continued Denial of Due Process
29. On March 12, 2025, Ms. Johnson submitted Open Public Records Act (OPRA) requests to Glen Ridge Police Department.
30. She received Anthony Mazza’s oath of office and limited records but did not receive bodycam footage and had trouble accessing the videos sent.
31. Ms. Johnson requested Sgt. Mazza’s surety and performance bonds, but Lt. Timothy Faranda stated those records were not maintained by the department.
32. In further correspondence, Ms. Johnson clarified that she had filed an ethics complaint with Internal Affairs and demanded confirmation of the police department’s insurance coverage.
33. She was informed that the Borough is a member of the Joint Insurance Fund and referred to the Borough Clerk, Tara Ventola, but no documentation of coverage or bonds was ever provided. Naomi informed Faranda based on the Constitution law is stated that all public official and public servant must have an oath on file and insurance.
V. Enforcement of Commercial Codes on a Private Woman
34. On July 16, 2025, Ms. Johnson sent an Affidavit of Status and Notice of Constitutional Violation to the NJ MVC Commsioner, addressing the misapplication of commercial statutes to her private conveyance.
35. She highlighted misleading statements on MVC forms that presume all registrants are commercial operators under 49 CFR and NJAC 13:60, despite having no option to opt-out or declare private status.
36. Ms. Johnson never received a response to this affidavit.
37. On June 2, 2025, Ms. Johnson served an Affidavit of Rebuttal and Notice of Constitutional Boundaries to Glen Ridge Police officials, asserting her private status and reserving all rights under constitutional law.
38. She demanded preservation of all bodycam, dashcam, and dispatch evidence. To date, she has not received full disclosure of this evidence.
39. On June 20, 2025, Ms. Johnson filed a tort claim with the Borough Risk Manager. It was forwarded to Internal Affairs and ignored.
VI. Bench Warrant, Failure of Notice, and Judicial Misconduct
40. On July 7, 2025, Ms. Johnson was informed by Lt. Faranda via email that a bench warrant had been issued. She had not received a second notice to appear.
41. On July 19, 2025, Ms. Johnson filed a Motion to Vacate and Quash the warrant and informed the court of her intent to remove the case to federal court under 42 U.S.C. §1983.
42. Ms. Johnson asserted due process violations, ADA non-compliance, lack of jurisdiction, and the court’s refusal to show cause or authority to proceed.
43. On July 28, 2025, Judge Mark Clemente admitted that the court was informed Naomi need not appear but simultaneously insisted a warrant was valid for failure to appear.
44. Judge Clemente offered to waive the warrant if Ms. Johnson paid the tickets, but ignored her motions, affidavits, and disability accommodation requests. He told her he will address it in court once sh,e appear.
45. Naomi wrote in most of her previous document that she will need the Show Cause document before the court date so she can properly defend her self. Naomi asked what was the cause of action. As a quasi criminal court Naomi requested for the Brady evidence from the prosecutor and if it is civil she will like to see a bound contract between her and a living man or woman.
46. The judge had the State of New Jersey verse Naomi Johnson. Based on Naomi’s understanding of the Sixth Amendment of the Constitution, Naomi have a right to face her accuser. She need to be able to cross examiner the accuser and witness in the case. A fiction entity like the State of New Jersey can not be the injuries party. Nor can the state sign a contract between the them.
47. Lt. asked Naomi come into the police state to be interview over the matter of her and Maza. Naomi called back and polite decline the interview. She suggest that she will send the Lt., an Affidavit on the incident between she and Anthony Maza. Naomi told Lt. She perfected a paper trail for both of their record. Also, Ms. Johnson declined to appear in person due to mistrust and fear of unlawful arrest and detention, stemming from the court's prior abuse of process.
48. The court ignored Ms. Johnson’s constitutional inquiries regarding the applicability of Title 39, 49 CFR, and her status as a private traveler.
49. She invoked her rights under the Fifth, Sixth, and Fourteenth Amendments, demanding to face her accuser if the proceeding is quasi-criminal couple of time in her documents.
50. The court never produced an injured party or a signed contract showing jurisdiction or commercial obligation, and refused to show proof of lawful authority over her body. The court also refuse to show proof of subject matter jurisdiction and territorial jurisdiction. Yet, the judge still requesting her to come to court. Then he said Naomi do not have to come into court but they issue a bench warrant.
51. On the Municipal Court website shows that Naomi do not have to come to court she can plead guilty or not guilty. Naomi did send an Answer before April 8th court date. Naomi was in compliance with the court procedure, yet the courts issued and unlawful bench warrant that was not properly served.
52. Ms. Johnson documented and served multiple filings from March through July 2025, which Naomi referred to as a "flood of documents," signaling judicial disregard for due process and legal inquiry.
53. As of the date of this Complaint, Ms. Johnson remains under threat of arrest, financial injury, and deprivation of rights, without remedy or relief.
IV. CONSTITUTIONAL VIOLATIONS
The police officer violated Naomi Fourth Amendment the right to free from Unlawful Search and Seizure. The seizure and towing of Naomi's vehicle without a warrant, probable cause tied to a crime, or exigent circumstances. Towing her vehicle for a possibly mistaken or expired registration (a civil violation) without a warrant or probable cause of a criminal offense, and without offering reasonable accommodations for her disability, constitutes a warrantless seizure of property.
Naomi’s Fourteenth Amendment of Due Process was violationed(Procedural and Substantive)
Violation: The towing and impoundment of her vehicle, issuance of a bench warrant, denial of her filings and motions, and lack of notice or hearing.
Procedural due process requires notice and an opportunity to be heard before the government deprives someone of life, liberty, or property.
• Naomi alleges she was not given timely or proper notice, judicial review, or a hearing before her vehicle was towed, or before the court issued a bench warrant.
• Her motions, affidavits, and evidence were ignored, violating her right to be heard.
3. First Amendment – Right to Petition the Government for Redress
Violation: Repeated refusal by officials to respond to Naomi’s affidavits, Notices of Claim, OPRA requests, and complaints.
• The First Amendment protects the right to petition the government for redress of grievances.
• Municipal officials repeatedly ignored Naomi’s formal legal documents, depriving her of meaningful redress.
4. Sixth Amendment – Right to Confront Accuser & Know Charges (If Proceeding Is Criminal)
Violation: Denial of her demand to confront her accuser, and refusal to produce evidence, a complainant, or a cause of action.
• The Sixth Amendment grants criminal defendants the right to be informed of the nature and cause of accusations, and to confront witnesses.
• If the court is treating this as quasi-criminal (as Naomi suggests by referencing fines, bench warrants, and judicial appearances), then she is entitled to these protections.
Naomi alleges the “State of New Jersey” was listed as plaintiff—a legal fiction incapable of testimony or cross-examination—raising Sixth Amendment concerns.
Eighth Amendment – Excessive Fines
Violation: Excessive impound and storage fees ($575.69) for a disputed, non-criminal infraction.
• The Eighth Amendment prohibits the imposition of excessive fines.
• Tow companies acting in concert with police to extract inflated impound fees for minor infractions may be state actors, triggering constitutional scrutiny.
Fourteenth Amendment – Equal Protection
Violation: Disparate treatment due to Naomi’s disability and pro se status.
• The Equal Protection Clause prohibits state actors from denying any person the equal protection of the laws.
• Naomi may argue that the towing and denial of accommodation, access to evidence, and refusal to engage with her filings reflect disparate treatment based on disability or perceived status (e.g., private traveler or “non-commercial” actor).
Americans with Disabilities Act (ADA), Title II – Failure to Accommodate
• Violation: No reasonable accommodation was made for Naomi’s disability after her vehicle was towed. She was left to walk home, and the police failed to consider her disability status when taking enforcement actions.
• Title II of the ADA prohibits discrimination by public entities.
• The failure to accommodate a person with a known disability (e.g., mobility impairment) during enforcement, especially where discretionary action is involved (like towing), may constitute an ADA violation.
Potential Conspiracy Under 42 U.S.C. §1983 and §1985
Violation: Coordination between police, court officials, and the towing company may amount to a conspiracy to deprive civil rights, particularly if there was:
• Collusion to silence or suppress her filings;
• Abuse of the bench warrant process;
• Knowing misapplication of law to justify seizure;
• Retaliation for asserting rights.
Relevant Statute:
42 U.S.C. §1985(3) – Conspiracy to interfere with civil rights.
V. RELIEF REQUESTED
The Plaintiff respectfully requests the Court to:
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Naomi Johnson respectfully demands judgment against all Defendants, jointly and severally, and requests the following relief:
1. Declaratory Judgment
a. Declaring that Defendants’ actions—including but not limited to the traffic stop, towing, seizure of Plaintiff’s private automobile, and issuance of a warrant—violated Plaintiff’s constitutional rights under the Fourth, Fifth, and Fourteenth Amendments;
b. Declaring that the Municipal Court of Glen Ridge acted without proper jurisdiction, in violation of Plaintiff’s due process rights;
c. Declaring that the Defendants failed to provide ADA accommodations in violation of the Americans with Disabilities Act (42 U.S.C. § 12101 et seq.);
d. Declaring that the towing and impoundment of Plaintiff’s vehicle violated the New Jersey Predatory Towing Prevention Act and Glen Ridge Municipal Code Chapter 10-05.
2. Injunctive Relief
a. Ordering the dismissal of all outstanding traffic tickets and any related proceedings;
b. Enjoining Glen Ridge Municipal Court, its judge, prosecutor, and administrative clerks from further unlawful administrative proceedings or enforcement actions without proving jurisdiction and affording full due process;
c. Enjoining E.C.R.B. Towing & Recovery from further attempts to charge illegal fees or transfer title to Plaintiff’s vehicle;
d. Requiring the immediate return or full reimbursement for the seizure, storage, and damage to Plaintiff’s vehicle;
e. Requiring Defendants to implement training and policy changes concerning ADA compliance, due process, and predatory towing.
3. Compensatory Damages
a. For all out-of-pocket expenses, towing and impound fees, loss of use of vehicle, medical distress, emotional suffering, and economic harm suffered due to the unlawful stop, seizure, prosecution, and denial of procedural due process.
4. Punitive Damages
Against individual Defendants (Sergeant Anthony Mazza, Judge Mark Clemente, Prosecutor Elizabeth Brewster, towing personnel, and any other government agents) for their intentional, malicious, or reckless disregard for Plaintiff’s constitutional and statutory rights.
Mental Pain And Emotional Distress
5. For a money judgment for mental pain and anguish and severe emotional distress, according to proof;
6. Nominal Damages
For the deprivation of Plaintiff’s rights where no compensatory damages may be awarded.
7. For a money judgment representing compensatory damages including consequential damages, lost wages, earning, and all other sums of money, together with interest on these amounts, according to proof;
8. Statutory Damages and Civil Penalties
a. Pursuant to 42 U.S.C. § 1983 and any applicable New Jersey civil rights or consumer protection statutes;
b. Pursuant to the New Jersey Predatory Towing Prevention Act.
9. Attorneys’ Fees and Costs
Under 42 U.S.C. § 1988 and all applicable statutes, even if pro se, Plaintiff reserves the right to seek fees if subsequently represented.
10. Other Relief the Court Deems Just and Proper
Including placing all named individuals on a Brady/Brady-Giglio list due to dishonesty or misconduct, and any other equitable relief in the interests of justice.
11. Award compensatory damages in the amount of $10,000,000 or For such other and further relief as the Court may deem just and proper.
Respectfully submitted,
_______________________________________
[Your Full Name]
[Date]
Comments
Post a Comment