UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
Naomi Johnson,
Plaintiff,
v.
Sergeant Anthony Maza
The Honorable Judge Mark Clemente
Elizabeth Brewster, Esq.
Denise C. Iandolo Administrator,
Violations Clerk
Defendant.
COMPLAINT FOR VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983
4. 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. https://www.slideshare.net/slideshow/the-united-states-district-court-for-the-district-of-new-jersey-pdf/283452897
5. 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”]
FACTUAL ALLEGATIONS – NOS 440
I. February 24, 2025 – The Unlawful Stop and Seizure of Naomi Johnson’s Conveyance
1. On Monday, February 24, 2025, in Glen 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 3 PM.
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 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. Sgt. Mazza did not offer to provide any accommodation after he towed Naomi’s conveyance, which displayed a handicap symbol on her license plate. She was left to walk home as a disabled 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. Detective Sergeant Daniel 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.
March 1 – March 3, 2025: Vehicle Registration and Towing Issues
14. On March 1, 2025, Ms. Johnson and her neighbor visited the New Jersey Motor Vehicle Commission (MVC) in Newark to verify registration status.
15. 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.
16. 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.
17. 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.
18. 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.
19. 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.
20. 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.
21. 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.
22. 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.
23. 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
24. Naomi read that under 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.
25. When Naomi received her personal conveyance, she noticed that writing had been placed on the right side of her windshield, displaying the towing date and other information. This writing has remained on her conveyance since February 24, 2025, and is still present on her front windshield as of September 25, 2025.
26. Naomi attempted to remove the writing but was unable to do so due to her disability. When she stands for too long or applies pressure on her right side, her tremors are triggered, causing her entire right side to shake involuntarily.
Legal Correspondence and Notices
25. 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
26. 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.
27. Naomi certified and mailed a Writ of Replevin on February 26, 2025, to reclaim her private conveyance before paying any excessive and unlawful fees to Chief Quinn, but he did not respond to the writ.
28. 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.
29. 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.
30. Naomi also sent a certified demand letter/True Bill on February 26, 2025, 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, on March 3, 2025.
31. Joe and Lynda both ignored Naomi’s letter.
32. 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.
33. 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.
34. 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.
35. Naomi has also reported this matter and the broader pattern of violations to multiple oversight and government agencies, including:
• Certified letter to New Jersey Department of Justice on March 12, 2025
• Certified letter to Washington DC Secretary of State on March 12, 2025
• Certified letter to New Jersey Attorney General’s Office of Civil Rights on March 12, 2025
• Certified letter to Secretary of the Treasury on March 12, 2025
• Certified letter to New Jersey Secretary of State on March 12, 2025
• Certified letter to Division of Consumer Affairs on March 12, 2025
• Certified letter to Federal Trade Commission on March 12, 2025
• Certified letter to Consumer Financial Protection Bureau on March 12, 2025
• Certified letter to U.S. Department of Justice on July 30, 2025
• Certified letter to New Jersey Motor Vehicle Commission, Trish Little-Floy, Acting Chief Administration, on July 12, 2025
• Certified letter to Essex County Courthouse Administrative, Samantha Mendenhall, Acting Administrative Director of the Courts, on September 5, 2025
• General mail to Anu Abraham, Municipal Division Manager, on September 5, 2025
• Township of Glen Ridge, Municipal Government
• State of New Jersey Office of the Attorney General
• Celeste Montensino, Deputy Chief Assistant Prosecutor
• Dawn Simonetti, Deputy Chief Assistant Prosecutor
• Theodore N. Stephens, II, Acting Essex County Prosecutor
Out of the above, only two entities responded. The New Jersey Attorney General’s Office of Civil Rights replied via email stating they did not have sufficient staff to take on the matter, suggesting Naomi reach out to civil rights attorneys. The Federal Trade Commission stated they do not handle cases like Naomi’s.
36. 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.
II. ADA Violations and Medical Hardship
37. Naomi Johnson is a medically disabled woman with chronic pain and mobility impairments, which limit her ability to walk long distances.
38. At the time of the February 24, 2025 stop, her handicap license plate clearly indicated her disability.
39. Sgt. Mazza did not provide any reasonable accommodation for her disability during the traffic stop or towing of her conveyance.
40. Naomi was forced to walk home cold temperatures, causing extreme physical and emotional distress.
41. Naomi requested an ADA-compliant process for vehicle retrieval, but both Glen Ridge Police Department and E.C.R.B. Towing failed to comply.
42. Naomi’s subsequent correspondence cited Title II of the Americans with Disabilities Act, emphasizing that public entities must provide equal access and reasonable accommodations in law enforcement procedures.
43. Glen Ridge Municipal Court ignored Naomi’s ADA complaints, further demonstrating systemic disregard for disabled citizens.
44. Naomi experienced heightened anxiety, depression, and PTSD symptoms due to the combination of unlawful seizure, denial of accommodation, and bureaucratic delays.
45. Naomi documented her medical hardship through her primary care physician, who confirmed that the February 24, 2025 incident exacerbated her existing conditions.
46. Naomi also experienced a severe flare-up of arthritis pain during the forced walk home and required additional medical treatment as a direct result of the incident.
47. Naomi requested reasonable accommodation in writing, including certified notices to the Glen Ridge Municipal Court and Police Department, which went unacknowledged.
48. Naomi did research and learned that the courts failure to provide accommodations constitutes a direct violation of her rights under the ADA and Section 504 of the Rehabilitation Act.
49. Naomi asserts that the cumulative impact of these violations has caused measurable financial, physical, and emotional harm.
III. Municipal Court Failures and Due Process Violations
50. Naomi filed a Motion to Dismiss and Notice to Show Cause with the Glen Ridge Municipal Court, challenging the validity of the traffic summons and bench warrant issued against her.
51. The Municipal Court failed to respond to her filings in a timely manner, effectively denying her due process rights under the Fourteenth Amendment.
52. Naomi was never issued a Failure to Appear notice or advised that a warrant had been issued against her, despite her correspondence and attempts to engage the court.
53. Glen Ridge Municipal Court presumes jurisdiction over Naomi’s person without evidence, despite her consistent assertion of private status and beneficial ownership of her conveyance.
54. Judge Mark Clemente, Municipal Court Administrator Denise C. Iandolo, and Prosecutor Elizabeth Brewster ignored Naomi’s notices, further violating her right to be heard and to contest charges before an impartial tribunal.
55. Naomi submitted a Notice of Default and Demand for Opportunity to Cure to the court, citing administrative failure and lack of jurisdiction, but received no acknowledgment.
56. Naomi maintains that the Municipal Court has no constitutional, equity, or statutory authority over her as a private woman, and any presumption to the contrary is null and void.
57. Naomi sent a Second Notice of Judicial Disqualification to Judge Mark Clemente, citing bias, conflicts of interest, and failure to adhere to judicial duties.
58. Naomi requested copies of any court orders, records, or communications related to the February 24, 2025 incident, but Glen Ridge Municipal Court failed to provide them.
59. Naomi asserts that the court’s inaction constitutes administrative overreach and a denial of fundamental rights under U.S. and New Jersey law.
60. Naomi sent all filings via certified mail and email, documenting delivery and receipt to ensure no claim of non-notice could be made.
IV. Judicial Correspondence and Coercion
61. On July 25, 2025, Naomi received an email from Judge Mark Clemente with a Borough of Glen Ridge Municipal Building letterhead referencing State of NJ v. Johnson.
62. The letter acknowledged receipt of several documents, including cover letters, affidavits, emails, and motions submitted by Naomi regarding pending charges in Glen Ridge Municipal Court.
63. The letter stated, “As Naomi understand it, your failure to appear has resulted in a bench warrant issued by my court. You have made a motion to vacate and/or quash and a motion to dismiss.”
64. The letter further stated, “You have been assigned a court date for August 5, 2025 at 4:00 PM, which is a live session. I will be hearing the motions and other applications you may wish to make at that time.”
65. Judge Clemente suggested, “As far as any accommodation, I would suggest that you make arrangements to enter through the Glen Ridge Public Library, which is the accessible route to the courtroom.”
66. The letter continued, “I am advised that neither of your tickets would necessarily require an appearance and that they could be paid online. If that is your intention, i.e., to pay them online, we can recall the warrant and you will not need to appear.”
67. The letter concluded, “Should you choose to appear, you should know that we would treat this appearance as your ‘first appearance’ on the above charges, which is the first step in the judicial process. We can conduct that, as well as the arraignment at that time, should you wish to make the appearance an arraignment.”
68. On August 1, 2025, Naomi emailed a six-page Response to the July 25, 2025 Judicial Letter/Demand to Appear. She addressed the coercive language suggesting payment of an unlawful traffic citation under threat of a bench warrant. Naomi stated that her response was made under protest, without waiver of rights, to preserve her liberty, due process protections, and prevent further injury.
69. Naomi responded to the judge’s statement regarding hearing motions by noting a willful refusal to address properly filed motions in advance of any hearing.
70. She cited Supreme Court precedent supporting her standing and the obligation of courts to rule on motions raising jurisdictional, procedural, or constitutional objections before compelling appearance.
71. Naomi informed the judge that she has not consented to any lawful contract with the State or Glen Ridge Municipal Court. She emphasized that no injured party, verified claim under penalty of perjury, or cause of action existed. Coercion to appear or pay without a lawful contract constitutes a violation of Article I, Section 10, Clause of the U.S. Constitution and Public Law 73-10/House Joint Resolution 192.
72. Naomi requested proof that the Glen Ridge Municipal Court has lawful judicial jurisdiction over a private woman not engaged in commercial activity and not subject to 49 CFR, Title 39, or 46 CFR. Silence by the court was noted as acquiescence.
73. Naomi highlighted that conditioning adjudication upon her physical presence under threat of a bench warrant operates outside due process protections.
74. She cited Presumption of Law vs. Facts in Evidence Rule 301, emphasizing the burden of producing evidence to rebut any presumption.
75. Naomi highlighted multiple constitutional violations, including denial of equal protection under the law, violations of unalienable rights, ADA noncompliance, and unlawful seizure and detention.
76. On September 25, 2025, Naomi certified a Notice and Demand for Full Accounting of Funds Held in the Court Registry.
77. On September 25, 2025, Naomi also certified a Notice & Demand related to the unlawful warrant and tickets.
78. Following certification of the Motion to Quash Warrant and Notice to Vacate Traffic Ticket, Naomi received two documents in response.
79. One response included a one-page email providing Glen Ridge’s official definitions of “motor vehicle,” “automobile,” and “conveyance,” demonstrating that her vehicle does not meet the criteria outlined on the court’s website.
80. The Borough’s licensing requirements primarily apply to businesses subject to police oversight and municipal ordinances, none of which apply to Naomi’s private conveyance.
81. Naomi has been subjected to harassment and coercion aimed at forcing her to relinquish constitutional rights as a private woman and one of the People.
82. The court continues to attempt to hold her accountable under commercial and administrative law, despite constitutional prohibitions.
83. Naomi cited Article I, Paragraph 2 of the New Jersey Constitution: “All political power is inherent in the people. Government is instituted for the protection, security, and benefit of the people, and they have the right at all times to alter or reform it, whenever the public good may require it.”
84. Naomi reminded government agents that the Preamble to the United States Constitution also emphasizes that government exists to serve the People.
85. Naomi asserted that administrative warrants are unconstitutional, and she, as one of the People, is entitled to judicial, not administrative, process.
86. She emphasized that public officials are trustees of the public trust and must uphold the Constitution, with violations constituting breach of trust.
87. Naomi explained that government officials violating the rights of the People are liable for penalties under the supreme law of the land.
88. She challenged Administrative Court Clerk/Violation Denise C. Iandolo to show delegated authority over her, a private woman, under the New Jersey Constitution.
89. On June 29, 2025, Naomi sent a Private Notice for Disqualification and Notice for Disqualification Violation.
90. On August 29, 2025, Naomi sent a Notice of Constitutional Duty and Liability.
91. On August 28, 2025, Naomi sent general mail to Sgt. Mazza with Personal Capacity Litigation notice.
92. Since February 24, 2025, the unlawful ticket and warrant caused deprivation of freedom of movement and fear of arrest.
93. The warrant lists Naomi’s race as “Black” on the traffic ticket and “Black/African American” on the warrant.
94. Naomi asserts that her accuser must be a living person, not a corporation such as the State of New Jersey. The court operates as a business under the State of New Jersey, violating constitutional rights.
95. Naomi received a court date of August 5, 2025, uploaded her Answer, Demurrer, and Affirmative Defense to the Municipal Court website, and sent copies via email to the Administrative Court Clerk, Prosecutor, and Judge.
96. She also sent a Private Judicial Notice directly to Judge Mark A. Clemente, demanding the removal of the unlawful warrant and the dismissal of the traffic tickets without prejudice. As of September 5, 2025, the warrant remains active, with a $500 unauthorized judgment/fine for which Naomi did not give express consent to the court opening an account in her name.
97. Naomi requested a reasonable accommodation in the form of a remote hearing; the judge suggested she appear at a library instead.
98. The ongoing situation caused mental, emotional, and physical suffering.
99. On August 27, 2025, Naomi submitted OPRA requests for certified public records from Judge Mark A. Clemente, Prosecutor Elizabeth Brewster, Court Administrator Denise C. Iandolo, Administrator Clerk Michael J. Rohal, including sworn oaths of office, surety bonds, and proof of delegated authority.
100. On September 23, 2025, Naomi requested records for Sgt. Anthony Maza, including complaints, disciplinary actions, internal investigations, issued traffic tickets, police manual, operational procedures, delegation of authority, and training documents. She received no documents.
101. On July 7, 2025, Lt. Timothy Faranda emailed Naomi a letter regarding Internal Affairs Complaint 25-5, Incident 25-05455, occurring February 24, 2025.
102. The IA investigation concluded that Sgt. Mazza followed policies and procedures under Title 39.
103. Naomi was overwhelmed and took months to review the email. On September 5, 2025, she submitted a formal rebuttal to the IA report, attaching her sworn Notice of Litigation and U.S. and NJ Constitution citations to Sgt. Mazza, Lt. Faranda, and Chief Sean P. Quinn.
104. On September 24, 2025, Naomi followed up with documents via email to Lt. Faranda.
105. On September 23, 2025, Naomi emailed Betty from records to request OPRA documents for Sgt. Mazza.
106. Naomi sent Court of Record – Notice of Liability to Sue to multiple parties including Deputy Chief Assistant Prosecutors, Chief Quinn, Lt. Faranda, Joe Strollo, E.C.R.B. Towing, Sgt. Mazza, and Detective Sergeant Daniel Manley.
107. She also sent Notice of Liability to Sue to Judge Mark Clemente, Prosecutor Elizabeth Brewster, Court Administrator Denise C. Iandolo, Acting Administrative Director Samantha Mendenhall, and Municipal Division Manager Anu Abraham.
108. Naomi checked the New Jersey Municipal Court website and observed that a bench warrant issued May 14, 2025 stated she did not have to appear in court and could plead guilty or not guilty. She uploaded her Answer/Demurrer and Affirmative Defense for the August 5th court date.
109. Naomi documented and served multiple filings from March through September 2025, which she described as a “flood of documents,” evidencing judicial disregard for due process. She filed documents on February 26, March 3, March 12, April 3, July 17, July 30, August 5, and September 5, 2025.
110. As of the filing of this Complaint, Naomi remains under threat of arrest, financial injury, and deprivation of rights without remedy or relief.
COUNTS OF VIOLATION
Count 1: Unlawful Stop and Seizure / Violation of Due Process (42 U.S.C. §1983)
Description:
Defendant Sergeant Anthony Mazza, acting under color of law, stopped and seized Ms. Naomi Johnson’s vehicle on February 24, 2025, without lawful cause or judicial authorization, violating her constitutional right to due process.
Subparagraphs / Relevant Facts:
1. Fact 1 – The stop occurred without probable cause or reasonable suspicion.
2. Fact 2 – Ms. Johnson provided identification and registration, but the officer continued the stop.
3. Fact 3 – Officer demanded submission to questioning without explaining legal justification.
4. Fact 4 – Ms. Johnson requested clarification on legal grounds for the stop; officer stated he pulled her over on probable cause, which is a high level of suspicious criminal act.
5. Fact 5 – Officer detain Ms. Johnson to tow her conveyance.
6. Fact 6 – Vehicle was taken from Ms. Johnson without her consent.
7. Fact 7 – Vehicle seizure was executed without court-issued warrant or lawful order.
8. Fact 8 – Tow company was summoned to seize vehicle immediately.
9. Fact 9 – Ms. Johnson was not given the opportunity to contest the seizure.
10. Fact 10 – Officer Mazza ignored to offer Ms. Johnson accommodation due to disability.
11. Fact 11 – Ms. Johnson was forced to walk home in cold weather.
12. Fact 12 – Vehicle seizure was recorded improperly in municipal logs.
13. Fact 23 – Officer did not provide any written citation or court notice at the time of stop.
14. Fact 24 – Municipal Court later issued an administrative warrant without Ms. Johnson’s knowledge.
15. Fact 41 – Court failed to respond to motions or affidavits challenging the seizure.
16. Fact 44 – Court denied Ms. Johnson procedural due process in all communications.
17. Fact 51 – Officer and court collectively ignored statutory requirements for proper seizure.
Count 2: Unauthorized Towing / Conversion of Property / Theft
Description:
E.C.R.B. Towing & Recovery, acting in conjunction with Glen Ridge Police Department, seized and withheld Ms. Naomi Johnson’s vehicle without her consent, without proper title, and imposed unlawful fees, constituting conversion, theft, and statutory violations under New Jersey Predatory Towing Prevention Act and Glen Ridge Borough Ordinances.
Subparagraphs / Relevant Facts:
1. Fact 6 – Sgt. Mazza had Ms. Johnson’s vehicle towed for being “unregistered.”
2. Fact 7 – Ms. Johnson did not consent to towing and was not presented with a judicial warrant.
3. Fact 8 – Vehicle displayed a handicap plate; no accommodations were offered.
4. Fact 15 – On March 1, 2025, E.C.R.B. Towing & Recovery was closed despite claiming 24-hour operation.
5. Fact 16 – E.C.R.B. employee confirmed weekend storage fees would apply even if closed; fee deemed predatory.
6. Fact 17 – Ms. Johnson returned to Glen Ridge Police and towing company with proof of registration.
7. Fact 18 – Towing and storage fees were quoted at $575.69, excessive and financially burdensome.
8. Fact 19 – Fees had substantially increased from earlier quotes (~$300) due to delay caused by closure.
9. Fact 20 – Employee itemized fees and admitted initiating title procedures before lawful timeframe.
10. Fact 21 – “Abandonment notice” fee applied unlawfully before 15–30 days period under NJ law.
11. Fact 22 – Ms. Johnson attempted to retrieve vehicle three times, but business was closed each time.
12. Fact 23 – E.C.R.B. failed to maintain office hours per NJ consumer protection regulations.
13. Fact 25 – Vehicle did not meet conditions for lawful towing under Glen Ridge Ordinance Chapter 10-05.
14. Fact 26 – Naomi certified Writ of Replevin on February 26, 2025; Chief Quinn did not respond.
15. Fact 29 – Naomi sent certified demand letter/True Bill to E.C.R.B., ignored by owner and management.
16. Fact 30 – Employee Bob failed to act on Ms. Johnson’s demand to return property.
17. Fact 31 – Police department claimed responsibility for tow; no reimbursement or compensation provided.
18. Fact 92 – Fear of arrest and inability to move freely caused deprivation.
19. Fact 93 – Race was listed on traffic ticket and warrant, adding discriminatory impact for racial profile on paper.
20. Fact (added from your follow-up) – Towing company wrote date and info on car window without consent, constituting vandalism/unauthorized marking.
21. Fact (added from your follow-up) – Vehicle was taken without title or permission, constituting theft.
22. Fact (added from your follow-up) – Joint action of towing company, police, and municipal court could be construed as conspiracy against Ms. Johnson.
23. Fact (added from your follow-up) – Misrepresentation of fees and unlawful seizure constitutes theft by deception.
If this structure works, I can move to Count 3: ADA Violations / Disability Accommodations, keeping the same format.
Count 3: ADA Violations / Disability Accommodations
Description:
Glen Ridge Police Department, Municipal Court, and related parties failed to accommodate Ms. Naomi Johnson’s disability, resulting in denial of access to her vehicle, court proceedings, and transportation, in violation of Title II of the Americans with Disabilities Act (ADA) and corresponding state protections.
Subparagraphs / Relevant Facts:
1. Fact 8 – Sgt. Mazza towed Ms. Johnson’s vehicle despite displaying a handicap plate; no accommodations offered, forcing her to walk home as a disabled woman.
2. Fact 97 – Ms. Johnson requested a reasonable accommodation for a remote hearing; the judge suggested she appear at a library instead, failing to accommodate her disability.
3. Fact 98 – Ongoing situation caused mental, emotional, and physical suffering due to lack of accommodation.
4. Fact 92 – Fear of unlawful arrest and inability to move freely exacerbated by lack of ADA accommodations.
5. Fact 25 (from later section) – Ms. Johnson’s travel patterns and therapy were affected due to anxiety from the incident, demonstrating denial of reasonable access and freedom of movement.
6. Fact 12 – Officer Manley acknowledged Ms. Johnson’s legal argument regarding travel without a commercial license, but deferred issues to federal courts, providing no immediate relief for her disability-related needs.
7. Fact 23 – Detective Sgt. Manley implied protection of the “blue wall of silence” rather than objectively addressing misconduct, resulting in lack of accommodation and safety assurances.
8. Fact 18 & 19 – Financial burden from excessive towing/storage fees further limited Ms. Johnson’s ability to meet her basic needs, compounding disability-related hardship.
9. Fact 26 – Ms. Johnson lacked funds for groceries due to towing fees, impacting her health and well-being.
10. Fact 27 – Payment on credit card created additional financial hardship, demonstrating indirect discrimination by failure to accommodate her status as a disabled individual.
Count 4: Due Process / Procedural Violations
Description:
Glen Ridge Police Department, Municipal Court, and related parties violated Ms. Naomi Johnson’s due process rights, including her rights to notice, hearing, and opportunity to contest charges, under the Fifth, Sixth, and Fourteenth Amendments to the U.S. Constitution, as well as corresponding state protections.
Subparagraphs / Relevant Facts:
1. Fact 7 – Ms. Johnson did not consent to seizure or towing of her vehicle and was not presented with a judicial warrant authorizing such action.
2. Fact 26 – Naomi certified and mailed a Writ of Replevin on February 26, 2025 to reclaim her conveyance; Chief Quinn did not respond.
3. Fact 27 – Naomi submitted a Notice of Default and Demand for Dismissal after her Motion to Dismiss and Notice to Show Cause were ignored.
4. Fact 28 – Certified Notice of Claim and Claim of Damages for Unlawful Summons sent to Borough Risk Management Officer Michael Zichelli, with no response.
5. Fact 29 – Certified demand letter/True Bill sent to E.C.R.B. Towing & Recovery; ignored by both owner and office manager.
6. Fact 31 – Police department failed to reimburse or compensate Naomi despite acknowledging responsibility for the tow.
7. Fact 40 – On July 7, 2025, Naomi informed by Lt. Faranda that a bench warrant had been issued; she had not received a second notice to appear.
8. Fact 41 – Naomi 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.
9. Fact 42 – Asserted due process violations, ADA non-compliance, lack of jurisdiction, and refusal to show cause or authority to proceed.
10. Fact 43 & 44 – Judge Clemente admitted Naomi need not appear but insisted a warrant was valid for failure to appear; offered to waive warrant if tickets paid, ignoring motions and disability accommodations.
11. Fact 45–54 – Court ignored Naomi’s requests for Show Cause documents, Brady evidence, proof of claim, subject matter and territorial jurisdiction, and proper service of process.
12. Fact 56–58 – Naomi immediately certified a Motion to Vacate and Quash Bench Warrant on July 16, 2025 and served Notice and Affidavit challenging jurisdiction.
13. Fact 60–67 – Judge Clemente acknowledged receipt of multiple filings but conditioned action on Naomi’s appearance; continued coercion under threat of warrant.
14. Fact 68–74 – Naomi responded under protest, preserving liberty and due process protections, highlighting presumption of law vs. evidence and lack of contract or injured party.
15. Fact 95–96 – Naomi uploaded Answer, Demurrer, and Affirmative Defense prior to August 5, 2025 court date; notified court via email and certified mail, yet unlawful warrant remained active.
16. Fact 110 – As of Complaint filing, Naomi remains under threat of arrest, financial injury, and deprivation of rights without remedy or relief.
Count 5: Unlawful Seizure / Theft / Predatory Towing
Description:
E.C.R.B. Towing & Recovery, in coordination with Glen Ridge Police Department, unlawfully seized Naomi Johnson’s private conveyance without consent, without judicial authorization, and imposed excessive and predatory fees, in violation of the New Jersey Predatory Towing Prevention Act, Glen Ridge Borough Ordinances, and Ms. Johnson’s constitutional and property rights.
Subparagraphs / Relevant Facts:
1. Fact 6 – Sgt. Mazza had Ms. Johnson’s conveyance towed for being “unregistered.”
2. Fact 7 – Ms. Johnson did not consent to the seizure or towing and no judicial warrant was presented.
3. Fact 8 – Sgt. Mazza did not provide any accommodation after towing Naomi’s vehicle that displayed a handicap plate; she was left walking home as a disabled woman.
4. Fact 15 – Ms. Johnson visited E.C.R.B. Towing & Recovery; facility was closed despite advertising 24-hour operation.
5. Fact 16 – E.C.R.B. employee confirmed weekend storage fees would apply even if closed; Naomi contends this is unfair and predatory.
6. Fact 17–18 – Naomi returned to Glen Ridge Police and towing company with proof of registration; was quoted $575.69, objected due to disability income.
7. Fact 19–20 – Previous calls quoted ~$300; employee itemized increased charges including storage, hook, yard, towing notification, credit card fee, and tax; admitted initiation of title procedures for “abandonment.”
8. Fact 21 – E.C.R.B. charged “abandonment notice” fee to initiate title transfer before lawful 15–30 day timeframe; unlawful attempt to convert property without due process.
9. Fact 22–23 – Naomi attempted retrieval on three occasions; company was closed; failed to comply with NJ law requiring reasonable access for after-hours vehicle release.
10. Fact 24 – Naomi asserted towing was unlawful, lacked judicial authorization, and amounted to theft; True Bill served to employee; manager never responded.
11. Fact 25 – Interaction documented with photos of spoiled food; financial hardship due to fees.
12. Fact 29 – Certified demand letter/True Bill to E.C.R.B. and hand-delivered copy to employee Bob; ignored by owner and manager.
13. Fact 31 – Told police responsible for tow; Naomi not reimbursed or compensated.
14. Fact 92–94 – Deprivation of freedom and harassment; potential racial profiling indicated; traffic court operating as a business under State of NJ umbrella.
15. Fact 100 – OPRA request for Anthony Maza’s traffic ticket records and training documentation not provided, preventing full accountability of police actions.
Count 6: ADA / Disability Rights Violations
Description:
Naomi Johnson, as a disabled woman, was denied reasonable accommodations and suffered unlawful discrimination in violation of Title II of the Americans with Disabilities Act (ADA). Her rights to access public services and programs were disregarded by Glen Ridge Police, Municipal Court, and E.C.R.B. Towing & Recovery.
Subparagraphs / Relevant Facts:
1. Fact 8 – Sgt. Mazza towed Naomi’s conveyance displaying a handicap symbol and did not provide accommodations; left to walk home as a disabled woman.
2. Fact 18 – Excessive towing and storage fees imposed on Naomi, a disabled woman on fixed income, causing financial hardship.
3. Fact 22–23 – E.C.R.B. failed to provide reasonable access for after-hours retrieval, despite advertising “24 Hour Service,” preventing Naomi from timely retrieving her vehicle.
4. Fact 25 – Denial of access and unreasonable fees directly impacted Naomi’s mobility, independence, and basic needs (e.g., groceries).
5. Fact 97 – Request for remote hearing ignored; judge suggested appearance at a library instead of accessible accommodations.
6. Fact 98 – Ongoing situation caused mental, emotional, and physical suffering, exacerbating her disability.
7. Fact 92 – Fear of leaving home due to unlawful warrant; inability to move freely constitutes ongoing ADA violation.
8. Fact 95 – Administrative Court Clerk, Prosecutor, and Judge ignored submissions indicating her disability; reasonable accommodations were not granted.
Summary:
The actions of Glen Ridge Police, Municipal Court, and E.C.R.B. Towing & Recovery collectively violated Naomi Johnson’s federally protected rights under Title II of the ADA, resulting in discrimination, undue hardship, and interference with her access to government services and the ability to safely travel in her personal conveyance.
Count 7: Due Process and Constitutional Violations
Description:
Naomi Johnson was deprived of her constitutional rights, including due process, equal protection, and the right to face her accuser, in violation of the Fifth, Sixth, and Fourteenth Amendments of the U.S. Constitution and related New Jersey constitutional provisions.
Subparagraphs / Relevant Facts:
1. Fact 7 – Vehicle seized without judicial warrant or consent.
2. Fact 25 – E.C.R.B. Towing & Recovery and Glen Ridge Police acted without due process in seizing property.
3. Fact 26–27 – Naomi served a Writ of Replevin and Notice of Default; court and police ignored filings, denying procedural rights.
4. Fact 28–33 – Certified Notices of Claim sent to multiple municipal officials and agencies; consistent refusal to respond demonstrates denial of remedy and due process.
5. Fact 44–54 – Bench warrant issued without proper notice or cause; court ignored constitutional inquiries and motions challenging jurisdiction and legal authority.
6. Fact 46–48 – Naomi requested cause of action and Brady evidence; court refused to identify a living accuser; the State of New Jersey, a fictional entity, cannot serve as the injured party.
7. Fact 51–54 – Court refused to produce proof of subject matter jurisdiction or territorial jurisdiction; yet issued warrant and compelled appearance.
8. Fact 56–58 – Motion to Vacate and Quash Bench Warrant filed immediately after being informed of unlawful warrant; court ignored and continued coercive enforcement.
9. Fact 68–74 – Judge Clemente’s July 25, 2025 letter attempts to coerce payment under threat of a bench warrant, refusing to address motions in advance, violating due process.
10. Fact 94 – Court operating under commercial framework (Dun & Bradstreet listing) rather than judicial process, depriving Naomi of constitutional protections.
11. Fact 110 – As of the filing of this complaint, Naomi remains under threat of arrest, financial injury, and deprivation of rights without remedy or relief.
Summary:
The Glen Ridge Police Department, Municipal Court, and associated officials acted to deprive Naomi Johnson of her constitutional rights, including due process, equal protection, and the right to face her accuser. These violations include unlawful seizure of property, coercive threats under color of law, refusal to acknowledge legal motions, and issuance of a bench warrant without lawful authority.
Count 8: Theft, Conversion, and Misappropriation of Property
Description:
Naomi Johnson’s private conveyance was unlawfully seized, retained, and charged fees without consent or legal authorization, constituting theft, conversion, and misappropriation under New Jersey law.
Subparagraphs / Relevant Facts:
1. Fact 7 – Vehicle seized and towed without judicial warrant or consent.
2. Fact 8 – No accommodations provided for disability; Naomi left to walk home.
3. Fact 16–22 – Towing company (E.C.R.B.) charged excessive fees, applied “abandonment notice” prematurely, and restricted access to vehicle despite 24-hour business claim.
4. Fact 25 – Vehicle did not meet any lawful towing criteria under Glen Ridge Borough Ordinance Chapter 10-05 or NJ Predatory Towing Prevention Act.
5. Fact 26 – Writ of Replevin served February 26, 2025; ignored by police and tow company.
6. Fact 29–31 – Certified letters and True Bills demanding return of property ignored; towing company and police refused reimbursement.
7. Fact 32–33 – Public records requested to document police and towing actions; refusal to respond prevented recovery of property rights.
8. Fact 42–44 – Bench warrant and court actions compounded the deprivation, preventing lawful recovery or access to property.
9. Fact 80 – Court and authorities attempted to enforce commercial or administrative law over private property, coercing Naomi into unlawful compliance.
10. Fact 92–93 – Threat of arrest and ongoing inability to freely travel caused deprivation of property use and liberty.
Additional Considerations:
• Unauthorized writing on the vehicle by towing company (date, tow company info) may constitute vandalism or graffiti.
• Seizure without title or consent constitutes theft by taking and conversion.
• Coordinated actions between towing company, police, and Municipal Court may constitute conspiracy to deprive property rights.
• Charging fees for services without lawful authorization or due process may constitute theft by deception.
Summary:
E.C.R.B. Towing & Recovery, the Glen Ridge Police Department, and Municipal Court officials unlawfully seized, retained, and attempted to profit from Naomi Johnson’s private conveyance, in violation of state and federal law, resulting in financial harm, loss of property, and deprivation of rights.
Count 9: ADA / Disability Rights Violations
Description:
Naomi Johnson, a medically disabled woman, was denied reasonable accommodations during the unlawful stop, seizure, and towing of her private conveyance. This constitutes violations of the Americans with Disabilities Act (ADA), Title II, and New Jersey disability access protections.
Subparagraphs / Relevant Facts:
1. Fact 8 – After towing her vehicle, Naomi was left to walk home despite clearly displaying a handicap symbol on her license plate.
2. Fact 18 – Excessive towing and storage fees imposed without consideration of her fixed disability income created financial and access hardship.
3. Fact 22–23 – Misleading business hours and lack of access to vehicle further exacerbated physical and logistical hardship, impeding her mobility.
4. Fact 97 – Request for reasonable accommodation in the form of a remote court hearing was denied; judge instead suggested she appear at a public library, creating physical barriers.
5. Fact 92 – Ongoing threat of arrest by the unlawful active bench warrant and inability to freely travel restricted her independence and ability to move safely.
6. Fact 98 – Mental, emotional, and physical suffering resulted from denial of accommodation and fear of unlawful detention.
Additional Considerations:
• The towing company’s failure to accommodate and the court’s insistence on in-person appearances ignored Naomi’s documented disability, creating systemic discrimination.
• Coordinated actions by police, tow company, and municipal court officials demonstrate a pattern of disregard for federally protected rights.
Summary:
Naomi Johnson’s right to equal access and reasonable accommodation under the ADA and New Jersey disability law was violated, causing physical hardship, emotional distress, and restricted mobility, directly resulting from the unlawful stop, towing, and coercive legal actions.
Count 10: Due Process Violations
Description:
Naomi Johnson was denied her constitutional right to due process under the Fifth and Fourteenth Amendments through multiple unlawful actions by the Glen Ridge Police Department, Municipal Court, and associated officials.
Subparagraphs / Relevant Facts:
1. Fact 7 – Ms. Johnson’s vehicle was seized without judicial authorization or warrant.
2. Fact 27 – Notice of Default and Demand for Dismissal ignored by the Glen Ridge Municipal Court after her Motion to Dismiss and Notice to Show Cause.
3. Fact 40–44 – Bench warrant issued without proper notice, despite Naomi not receiving a second court notice or being required to appear.
4. Fact 45–48 – Court refused to provide Show Cause document, cause of action, or evidence of an injured party, denying Naomi the ability to confront her accuser.
5. Fact 51–54 – Court ignored constitutional inquiries regarding Title 39, 49 CFR, and her private traveler status, and failed to establish subject matter and territorial jurisdiction.
6. Fact 57–58 – Naomi complied with court procedure by submitting an answer/demurrer but was still subject to an unlawful, improperly served bench warrant.
7. Fact 68–70 – Judge’s communication coerced payment of traffic citations under threat of a bench warrant, and refused to rule on pre-filed motions before compelling appearance.
8. Fact 71–74 – Court refused to provide lawful proof of jurisdiction or cause of action, conditioning adjudication on appearance under threat of arrest.
9. Fact 95–96 – Naomi’s filings including Answer, Demurrer, and Affirmative Defense were ignored, yet the court continued to threaten her with arrest.
10. Fact 108–110 – Bench warrant improperly issued, and despite multiple filings from February through September 2025, Ms. Johnson remains under threat of arrest and deprivation of rights without remedy.
Additional Considerations:
• Multiple failures by court officials to acknowledge filings, respond to certified correspondence, or provide notice demonstrate a pattern of willful disregard for due process.
• Actions taken under threat of arrest coerced compliance with unlawful procedures, violating both procedural and substantive due process rights.
Summary:
Naomi Johnson’s rights to notice, to confront an accuser, to be heard, and to due process under the law were systematically violated, resulting in continued legal jeopardy, emotional distress, and restriction of her personal liberty.
Count 11: Unlawful Seizure / Theft / Conversion of Property
Description:
Naomi Johnson’s personal conveyance was seized, towed, and held without judicial authorization, resulting in unlawful conversion, financial harm, and deprivation of property rights.
Subparagraphs / Relevant Facts:
1. Fact 6–8 – Sgt. Mazza claimed he would have Naomi’s conveyance towed for being “unregistered”, without consent or a judicial warrant. Ms. Johnson was not offered ADA accommodations and left to walk home as a disabled woman.
2. Fact 17–21 – Naomi attempted to retrieve her vehicle, but the towing company charged excessive fees, including storage, hook, yard, and abandonment notice fees, and attempted to initiate title transfer before the lawful 15–30 day period.
3. Fact 22–23 – Naomi attempted three separate retrievals from the towing company, but access was denied despite advertising “24-hour service,” violating NJ consumer protection regulations.
4. Fact 25–26 – Writ of Replevin submitted to reclaim property and certified mailed to the police department, but no response was received, leaving the conveyance in unlawful possession of the tow company.
5. Fact 29–31 – Certified demand letters to the towing company ignored by both the owner and manager, with the police department claiming responsibility for the tow, failing to provide reimbursement or resolution.
6. Fact 92–94 – Naomi remained deprived of freedom of movement, fearing arrest under unlawful claims, while the vehicle was marked on the right side window with towing date and company info without her permission.
7. Fact 103–104 – Naomi filed a rebuttal to Internal Affairs Report, highlighting unauthorized seizure and retention of property as a continuing violation.
Additional Considerations:
• The towing company marked Naomi’s vehicle without consent, which may constitute vandalism or graffiti.
• The seizure and retention of her vehicle without title or judicial authorization may constitute theft or conversion of property.
• Actions by the police, municipal court, and towing company may suggest conspiracy to deprive Naomi of her property and rights.
• Charging excessive and predatory fees under threat of forced compliance can also be considered theft by deception.
Summary:
Naomi Johnson’s personal conveyance was unlawfully seized, withheld, and monetized without legal authority, resulting in deprivation of property, financial harm, ADA violations, and ongoing threats of coercion.
Count X: Unauthorized Account Creation / Deprivation of Property / Misuse of Judicial Authority
Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.
1. On or about February 24, 2025, the Glen Ridge Municipal Court, through its Judge, Prosecutor, and Administrative Court Clerk, imposed a $500 “warrant” in Plaintiff’s name.
2. At no time did Plaintiff provide consent, execute any financial instrument, or authorize any monetary obligation connected to the said warrant.
3. The imposition of this financial obligation resulted in the effective creation of an account or liability in Plaintiff’s name, without notice, due process, or lawful authority, and without lawful application of Title 39, New Jersey motor vehicle laws, or municipal ordinances.
4. Defendants’ conduct constitutes a deprivation of Plaintiff’s property and financial interest in violation of the Due Process Clause of the Fifth and Fourteenth Amendments of the U.S. Constitution, and Article I, §§ 1, 7, 18 of the New Jersey Constitution.
5. By creating or causing a financial obligation without lawful authority, the Defendants committed abuse of process, conversion, and trespass against Plaintiff’s property interests.
6. Defendants misapplied statutes and codes for the purpose of creating a financial obligation, in direct conflict with constitutional protections and Plaintiff’s unalienable rights.
7. Defendants, as judicial officers, breached their fiduciary and constitutional oath to uphold the laws and constitutions of the United States and New Jersey, resulting in harm to Plaintiff.
6. RELIEF REQUESTED
The Plaintiff respectfully requests the Court to:
7. 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]
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