DECLARATION OF COMPLAINT
State of New Jersey
County of Essex
I, Naomi Johnson, mailing address provision is Glen Ridge, New Jersey 07028, being duly sworn, depose and state the following under penalty of perjury:
1. Incident Overview
1. On February 24, 2025, Officer Anthony D. Mazza of the Glen Ridge Police Department, Glen Ridge Municipal Court, 825 Bloomfield Ave, Glen Ridge, NJ 07028, unlawfully ordered my vehicle to be towed by E.C.R.B. Towing & Recovery, located at 329 Broad Street, Bloomfield, NJ 07003.
2. Officer Mazza falsely claimed I failed to stop at a stop sign and that my vehicle was "unregistered." However:
◦ I did stop at the stop sign, and there was no proof that I failed to do so.
◦ My vehicle was not unregistered—it may have needed renewal, but it was not legally "unregistered" under NJ law.
3. The officer had no legal basis to tow my vehicle under Glen Ridge Borough Ordinance Chapter 10-05, which outlines the conditions under which a vehicle may be impounded.
4. N.J.S.A. 40:48-2-49 regulates towing services, including non-consensual towing and the removal of vehicles under specific circumstances as followed…
• Abandoned
• Disabled
• Illegally parked
• Involved in a motor vehicle crash
• Stolen and recovered
• Suspected or identified as being involved in a criminal act
5. The towing of my vehicle was unlawful and predatory, violating my rights and state law.
2. Violations of the Predatory Towing Prevention Act (N.J.S.A. 56:13-7 to 56:13-23)
The actions of E.C.R.B. Towing & Recovery, in collaboration with Glen Ridge Police Department, violated multiple provisions of the New Jersey Predatory Towing Prevention Act:
(A) Unlawful Non-Consensual Towing (N.J.S.A. 56:13-9)
• My vehicle was towed without my consent under circumstances not authorized by law.
(B) Failure to Provide Required Notice and Information (N.J.S.A. 56:13-14)
• E.C.R.B. Towing & Recovery did not provide a written statement detailing the towing fees or reason for the tow beforehand.
(C) Charging Excessive or Unauthorized Fees (N.J.S.A. 56:13-16)
• E.C.R.B. Towing attempted to charge an abandonment notice fee and threatened to claim my vehicle title before the legal time frame of 15-30 days.
(D) Failure to Provide Reasonable After-Hours Release (N.J.S.A. 56:13-15)
• I attempted to retrieve my vehicle three times, but the business was closed, despite advertising 24-hour service.
(E) Violation of Storage Fee Limits (N.J.S.A. 39:10A-1)
• E.C.R.B. Towing attempted to charge unauthorized storage fees and falsely claimed the right to seize my vehicle title before the required waiting period.
3. Police Department’s Complicity in Predatory Towing (N.J.S.A. 56:13-21)
• The Glen Ridge Police Department engaged in predatory towing practices by ordering the unlawful tow and failing to provide any legal justification.
• The police ethics department misrepresented the legality of the tow and the issuance of two citations against me.
4. Constitutional and Disability Rights Violations
• Fourth Amendment Violation: My vehicle was unlawfully seized without a warrant, probable cause, or legal justification.
• Fourteenth Amendment Violation: My property was taken without due process.
• Disability Rights Violations: The loss of my vehicle caused me physical distress and financial hardship.
• Failure to Provide a Reasonable Modification (28 C.F.R. § 35.130(b)(7))
• Financial Loss: My groceries spoiled over seven days due to the unlawful seizure of my vehicle.
5. Demands for Investigation and Remedies
I demand the following actions:
1. A full investigation into Officer Anthony D. Mazza (Badge #86) for misconduct and abuse of authority.
2. A full investigation into E.C.R.B. Towing & Recovery for predatory towing, fraudulent charges, and illegal attempts to seize my vehicle.
3. Immediate reimbursement of all towing fees, storage fees, and financial losses.
4. Dismissal of the two tickets and removal of traffic violation points from my driving record.
5. Corrective action against Glen Ridge Police Department for participating in predatory towing practices.
6. Policy changes to prevent further abuse of power regarding vehicle towing.
I submit this declaration in good faith, under penalty of perjury, attesting that the facts herein are true to the best of my knowledge.
Sworn and Subscribed Before Me
On this 8th day of March, 2025, before me, a Notary Public in and for the State of New Jersey, personally appeared Naomi Johnson, who, being duly sworn, deposes and states that the foregoing is true and correct.
By: Naomi: Johnson
Authorized Representative, Beneficiary
Without Prejudice, UCC 1-308
All Rights Reserved
NOTARY PUBLIC ACKNOWLEDGMENT:
State of _____________
County of ____________
On this ___ day of _________, 20, before me, a Notary Public in and for the State of _____________, personally appeared Naomi: Johnson, known to me (or satisfactorily proven) to be the person.
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