COMPLAINT FOR VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

NATURE OF THE ACTION

1. Plaintiff Naomi Johnson brings this civil rights action under 42 U.S.C. §§ 1983 and 1985, the Fourth, Fifth, and Fourteenth Amendments to the United States Constitution, the New Jersey Constitution, and related laws, seeking redress for unlawful acts committed under color of state law.

PRELIMINARY STATEMENT

1. This is a civil rights action to vindicate fundamental liberties guaranteed under the United States Constitution, the New Jersey Constitution, and binding human rights law. Plaintiff Naomi Johnson brings this action seeking injunctive, declaratory, and monetary relief against Defendants for violations of her rights under the Fourth, Fifth, and Fourteenth Amendments, 42 U.S.C. §§ 1983 and 1985, the Americans with Disabilities Act (ADA), and the New Jersey Law Against Discrimination (NJLAD), N.J.S.A. 10:5-1 et seq., also known as the New Jersey Human Rights Law.

2. The rights at stake in this case are not new creations of statute; they are deeply rooted in the foundational charters of liberty, including the Magna Carta (1215), the English Bill of Rights (1689), the Declaration of Independence (1776), and the United States Bill of Rights (1791). These charters affirm that government exists to serve the people and is bound to respect inherent and unalienable rights.

3. Plaintiff also invokes the principles of natural law and international human rights treaties binding upon the United States, including the International Covenant on Civil and Political Rights (ICCPR) and the Universal Declaration of Human Rights (UDHR), which recognize the dignity, liberty, and equality of all persons.

4. Defendants, acting under color of law and in conspiracy with one another, deprived Plaintiff of her liberty, property, and due process by means of an unlawful traffic stop, seizure, towing, administrative warrant, and prosecutorial misconduct. In so doing, Defendants ignored their sworn oaths of office and breached the public trust doctrine, in violation of constitutional mandates, statutes, Blackstone’s Commentaries,, common law maxims, and Plaintiff’s Notice of Sovereignty (NOS 440), which expressly preserved her rights and status.

5. Accordingly, Plaintiff Naomi Johnson brings this action to secure redress for trespass upon her rights, deprivation of due process and equal protection, unlawful seizure of property, discrimination on the basis of disability, and conspiracy to interfere with civil rights. Plaintiff seeks injunctive relief, declaratory relief, and monetary damages in the amount of Ten Million Dollars ($10,000,000) to remedy the injuries caused by Defendants’ unlawful actions.

6. Defendants also engaged in racial profiling and discriminatory treatment by recording Plaintiff’s race as “Black” on the traffic citation. The practice of documenting race in traffic enforcement actions serves no legitimate law enforcement purpose and instead creates an impermissible risk of disparate treatment, unequal application of law, and discriminatory prosecution once such documents are submitted to the Municipal Court or township. Plaintiff has no assurance that her case is not being influenced by racial bias within the police department, municipal court, or township government. This practice constitutes a violation of the Equal Protection Clause of the Fourteenth Amendment, the Civil Rights Act of 1964, and the New Jersey Law Against Discrimination, N.J.S.A. 10:5-1 et seq and Whren v. United States (517 U.S. 806, 1996) (equal protection claims for racially motivated traffic stops)

4. I. JURISDICTION

This action arises under the Constitution and laws of the United States, including 42 U.S.C. § 1983, the Fourth, Fifth, and Fourteenth Amendments to the U.S. Constitution, and Title II of the Americans with Disabilities Act (ADA).

• Jurisdiction is proper in this Court under 28 U.S.C. §§ 1331 and 1343 because this case presents federal questions involving deprivation of civil rights under color of law.

• Venue is proper in this District under 28 U.S.C. § 1391(b) because the events giving rise to this claim occurred in Essex County, New Jersey.

Introduction

1. Plaintiff, Naomi Johnson, is a natural, living woman, appearing Sui Juris, asserting her rights solely as a private individual under the U.S. Constitution, common law, natural law, and her unalienable rights as a member of We the People.

2. Plaintiff expressly rejects any statutory, corporate, or commercial designations, including the labels “person,” “pro se,” or any government-created entity. She does not consent to be treated as a statutory or corporate entity.

3. Plaintiff brings this action to protect her constitutional, civil, and natural rights, including the rights to due process, equal protection, freedom from unlawful seizure, and access consistent with disability protections under the Americans with Disabilities Act and corresponding New Jersey law.

4. Plaintiff’s vehicle and personal property were unlawfully seized, detained, and monetized by defendants acting under color of law, resulting in violations of federal and state law, including 42 U.S.C. §1983, the New Jersey Predatory Towing Prevention Act, and other rights enumerated herein.

5. Plaintiff seeks declaratory, injunctive, and compensatory relief, and reserves all rights afforded under the U.S. Constitution, Magna Carta, Declaration of Independence, common law, and unenumerated natural rights.

PARTIES

1. Plaintiff: Naomi Johnson is a “beneficial owner” and resident of the State of New Jersey. She brings this action to protect her civil rights, constitutional rights, and property rights.

2. Defendants:

a.State of New Jersey – a fictitious entity, sued in its official capacity because Judge Mark Clemente named the State as the party versus Plaintiff Naomi Johnson. The State is being sued for actions taken under color of law.

b. Glen Ridge Township – a fictitious municipal entity responsible for the administration of the Glen Ridge Police Department, Municipal Court, and municipal policies affecting Plaintiff.

c. E.C.R.B. Towing – a corporate/fictitious entity engaged in the towing and impoundment of Plaintiff’s vehicle without lawful consent.

d. Sergeant Anthony Mazza – sued in both his private and professional capacities as an officer of the Glen Ridge Police Department who participated in the unlawful stop, seizure, and impoundment of Plaintiff’s conveyance.

e. The Honorable Judge Mark Clemente – sued in both his private and professional capacities for actions taken in his judicial role that exceeded jurisdiction and violated Plaintiff’s constitutional and civil rights.

f. Elizabeth Brewster, Esq. – Borough Prosecutor, sued in both her private and professional capacities for participation in prosecutorial actions that deprived Plaintiff of due process and facilitated unconstitutional enforcement.

g. Denise C. Iandolo, Municipal Court Administrator / Violations Clerk – sued in both her private and professional capacities for administrative actions that contributed to the unlawful processing of citations, warrant issuance, and denial of Plaintiff’s rights.

h. Detective Sergeant Daniel Manley – sued in both his private and professional capacities for actions or omissions that violated Plaintiff’s civil and constitutional rights under color of law.

i. Lt. Timothy Faranda – sued in both his private and professional capacities for conducting an investigation into Sgt. Mazza’s actions, stating Mazza followed “policy” while failing to address violations of law, statutes, and the sworn constitutional oath of Sgt. Mazza to uphold the New Jersey and United States Constitutions.

j. Chief of Police Sean P. Quinn – sued in both his private and professional capacities for failing to respond to Plaintiff’s certified Writ demanding the release of her unlawfully towed conveyance, causing deprivation of property and harm.

K. Glen Ridge Borough Administrator Michael Rohal – sued in both his private and professional capacities for failing to provide Plaintiff access to public records requested under OPRA, obstructing Plaintiff’s ability to investigate and document her claims, and contributing to the deprivation of her rights.

L. Michael Zichelli, Risk Manager of the Borough of Glen Ridge – sued in both his private and professional capacities for failing to respond to Plaintiff’s Tort Claim regarding Sgt. Mazza’s unlawful conduct, improperly forwarding Plaintiff’s evidence (photos, towing receipts, fee schedules) to Internal Affairs instead of responding directly, and thereby enabling ongoing violations of Plaintiff’s civil and constitutional rights.

Joe Strollo – individually and professionally, as owner/operator of E.C.R.B. Towing who participated in the unlawful seizure, towing, and retention of Plaintiff’s conveyance. Defendants were required to comply with the Predatory Towing Act and other applicable statutes, and their failure to do so contributed to Plaintiff’s deprivation of rights.

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 12: 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.

Count 13 – Racial Profiling and Equal Protection Violations

Plaintiff realleges and incorporates by reference paragraphs 1 through ___ of this Complaint as if fully set forth herein.

1. Defendants recorded Plaintiff’s race as “Black” on a traffic citation issued on February 24, 2025.

2. The inclusion of Plaintiff’s race on the citation serves no legitimate law enforcement purpose and creates a risk of disparate treatment, discriminatory prosecution, and unequal application of law.

3. By documenting Plaintiff’s race and submitting such citations to the Municipal Court and Glen Ridge Township authorities, Defendants knowingly exposed Plaintiff to discriminatory treatment and racial bias in violation of her constitutional rights.

4. Plaintiff has no assurance that the Municipal Court, township, or police department treated her case fairly or without racial prejudice.

5. The acts and omissions of Defendants constitute racial profiling and a violation of the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution.

6. Defendants’ actions also violate 42 U.S.C. § 1981, 42 U.S.C. § 1983, Title VI of the Civil Rights Act of 1964, and the New Jersey Law Against Discrimination (N.J.S.A. 10:5-1 et seq.).

7. As a direct and proximate result of Defendants’ actions, Plaintiff has suffered harm, including but not limited to emotional distress, humiliation, fear of unequal treatment, and deprivation of civil rights.

Count 14– Deprivation of Property / Trespass Under Color of Law

Plaintiff Naomi Johnson alleges that on or about February 24, 2025, Defendant E.C.R.B. Towing, owned by Joe Strollo, unlawfully seized Plaintiff’s private conveyance without her consent and without any court order or statutory authority permitting such action. At the direction of Sergeant Anthony Mazza of the Glen Ridge Police Department, the towing company impounded Plaintiff’s vehicle despite the absence of legal authorization, knowledge, or consent from Plaintiff, the rightful owner.

Defendants acted under color of law in coordination with the police and municipal officials, relying on the purported authority of a police call rather than compliance with New Jersey Title 39, the Predatory Towing Act, or other applicable statutes and regulations. The towing of Plaintiff’s vehicle without consent constitutes trespass, conversion, deprivation of property, and violation of Plaintiff’s civil rights under 42 U.S.C. §1983.

Plaintiff further alleges that Defendant Strollo, as owner of the towing company, was aware or should have been aware of the legal requirements for towing private property, including obtaining the owner’s consent or a lawful court order, and his failure to comply constitutes willful disregard for Plaintiff’s rights.

As a direct and proximate result of Defendants’ actions, Plaintiff suffered loss, interference with her property, emotional distress, and deprivation of her civil liberties, for which she seeks compensatory, declaratory, and injunctive relief.