AFFIDAVIT OF NON-RESPONSE
UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY
NAOMI JOHNSON, Affiant,
v.
SERGEANT ANTHONY D. MAZZA, et al., Respondents.
Case No.: [To be assigned]
I, Naomi Johnson, a living woman, of sound mind and over the age of majority, residing in the State of New Jersey, do hereby solemnly affirm, declare, and state under penalty of perjury pursuant to 28 U.S.C. § 1746 that the following facts are true and correct to the best of my knowledge and belief:
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On February 24, 2025, I was stopped by Sergeant Anthony D. Mazza of the Glen Ridge Police Department in Glen Ridge, New Jersey, while operating my private vehicle. Sgt. Mazza stated the reason for the stop was my alleged failure to stop at a stop sign.
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During the stop, I asked Sgt. Mazza to state the purpose of the stop and whether I had committed any crime. Sgt. Mazza questioned how I knew the term “articulable suspicion” and stated he stopped me based on “probable cause” but provided no specific facts to support this claim.
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Sgt. Mazza demanded my driver’s license, vehicle registration, and proof of insurance. I provided the requested documents under protest, as I had not committed any crime.
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Sgt. Mazza ordered my vehicle to be towed, stating it was unregistered. My vehicle displayed a handicap symbol on the license plate, indicating my disability. Despite this, Sgt. Mazza did not offer assistance, contact a supervisor, or arrange transportation for me. I was forced to walk home alone.
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Sgt. Mazza recorded my race on the traffic ticket issued during the stop.
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I submitted a Motion to Dismiss, Notice to Show Cause, Challenge of Jurisdiction, and other supporting documents to the Glen Ridge Municipal Court. The traffic citation did not require my appearance in court. The Glen Ridge Municipal Court issued a warrant in my name for failure to appear.
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I sent certified mail to various public officials, public servants, and agencies to address the incident, the towing of my vehicle, and the warrant. The following is a record of those communications, the specific actions or inactions of the recipients based on my personal knowledge, and the lack of responses:
- Glen Ridge Police Department, Chief Sean Quinn, 3 Herman Street, Glen Ridge, NJ 07028, February 26, 2025: I sent a Writ of Replevin requesting the return of my vehicle. Chief Quinn did not respond or take action to return my vehicle or address my complaint against Sgt. Mazza. No response was received.
- Borough of Glen Ridge Municipal Court, 825 Bloomfield Avenue, Glen Ridge, NJ 07028, February 26, 2025: I sent the two traffic tickets issued to me. The court did not acknowledge or process my request to dismiss the tickets. No response was received.
- E.C.R.B. Towing, Joe Strollo, 329 Broad Street Rear, Bloomfield, NJ 07003, February 26, 2025: I sent a True Bill stating that the towing was without my consent or authorization and demanded the release of my vehicle. Joe Strollo did not release my vehicle or contact me. I paid $575.69 on March 3, 2025, to recover my vehicle. No response was received.
- Borough of Glen Ridge Municipal Court, March 12, 2025: I sent a Motion to Dismiss and Notice to Show Cause. The court did not acknowledge or act on my filings. No response was received.
- New Jersey Department of Treasury, 1125 West State Street, Trenton, NJ 08625, March 12, 2025: I sent a letter to address the traffic tickets and towing fee. The Department did not contact me or take action to address my request. No response was received.
- Washington, DC Secretary of State, 1350 Pennsylvania Avenue NW, Suite 419, Washington, D.C. 20220, March 12, 2025: I sent a letter to address the traffic tickets and towing fee. The Secretary did not contact me or take action. No response was received.
- New Jersey Attorney General, 25 Market Street, Trenton, NJ, March 12, 2025: I sent a letter about the towing and treatment by Glen Ridge police. The Attorney General’s office did not contact me or investigate the matter. No response was received.
- Secretary of the Treasury (U.S.), 1500 Pennsylvania Avenue NW, Washington, DC 20220, March 12, 2025: I sent a letter to address the traffic tickets and towing fee. The Secretary did not contact me or take action. No response was received.
- New Jersey Secretary of State, PO Box 300, Trenton, NJ 08625, March 12, 2025: I sent a letter about the towing and treatment by Glen Ridge police. The Secretary did not contact me or investigate. No response was received.
- Division of Consumer Affairs, PO Box 45025, Newark, NJ 07101, March 12, 2025: I sent a letter about the towing fee and business practices of E.C.R.B. Towing. The Division did not contact me or take action. No response was received.
- Federal Trade Commission (FTC), 600 Pennsylvania Avenue NW, Washington, DC 20580, March 12, 2025: I sent a letter about the towing fee and business practices. The FTC responded that they could not assist but did not investigate further.
- Consumer Financial Protection Bureau (CFPB), 1700 G Street NW, Washington, DC 20552, March 12, 2025: I sent a letter about the towing fee and business practices. The CFPB did not contact me or take action. No response was received.
- Disability Rights Section (U.S. DOJ), 950 Pennsylvania Avenue NW, Washington, DC 20530, March 12, 2025: I sent a letter about the lack of accommodation by Glen Ridge police after the towing, noting that I was forced to walk home despite my disability. The DOJ responded that they could not assist due to staffing and caseload limitations but did not investigate further.
- Glen Ridge Municipal Court, Attn: Elizabeth Brewster (Prosecutor), April 3, 2025: I sent a Motion to Dismiss, an affidavit, proof of spoiled food caused by the towing, a tow receipt, a Writ of Replevin, and a photo of my license plate showing the handicap symbol. Prosecutor Brewster did not acknowledge or act on my filings. No response was received.
- Glen Ridge Municipal Court, Attn: Denise C. Iandolo (Administrative Court Clerk), April 3, 2025: I sent a Notice of Default, Notice to Cure, Motion to Dismiss, affidavit, proof of spoiled food, tow receipt, Writ of Replevin, and handicap license plate photo. Clerk Iandolo did not acknowledge or process my filings. No response was received.
- Risk Manager Claim, Michael Zichelli, Borough Administration, Glen Ridge, NJ 07028, April 6, 2025: I sent a tort claim, proof of spoiled food, traffic ticket, towing receipt, and handicap license plate photo. Mr. Zichelli did not contact me or address my claim. No response was received.
- Risk Manager Claim, Attn: Tisha Brooks, Essex County Hall of Records, RM 414, 465 Dr. Martin Luther King Jr., Newark, NJ 07102, April 26, 2025: I sent a claim. Inservco Insurance Service, Inc., through Sureatha N. Hobbs, responded that they are not associated with Glen Ridge and took no further action.
- Glen Ridge Police Department, Lt. Timothy P. Faranda, June 5, 2025: I sent an affidavit and other materials. Lt. Faranda emailed to confirm receipt and stated an investigation into Sgt. Mazza would be conducted but did not address the substance of my documents or provide further updates.
- Glen Ridge Municipal Court, Attn: Elizabeth Brewster, Esq., July 17, 2025: I sent a Motion to Quash Warrant, Notice to Vacate Traffic Ticket, evidence of disability, tow reimbursement receipt, affidavits, and a copy of my registration form. Prosecutor Brewster did not acknowledge or act on my filings. No response was received.
- Glen Ridge Municipal Court, Attn: Honorable Judge Mark Clemente, July 17, 2025: I sent a Motion to Quash Warrant, Notice to Vacate Traffic Ticket, evidence of disability, tow reimbursement receipt, affidavits, and a copy of my registration form. Judge Clemente acknowledged receipt, stated the warrant was due to failure to appear (though I was not required to appear), and offered to treat my appearance as first-time or dismiss upon payment. He did not address the substance of my filings or provide further response.
- Glen Ridge Municipal Court, Attn: Denise C. Landolol, July 17, 2025: I sent a Motion to Quash Warrant, Notice of Default, evidence of disability, tow reimbursement, affidavits, and registration form copy. Clerk Landolol did not acknowledge or process my filings. No response was received.
- New Jersey Motor Vehicle Commission, Attn: Trish Little, PO Box 403, Trenton, NJ 08666, July 17, 2025: I sent a letter addressing issues with my registration form. Ms. Little did not contact me or address my concerns. No response was received.
- Glen Ridge Municipal Court, Attn: Honorable Judge Mark Clemente, July 30, 2025: I sent a Judicial Notice for Disqualification. Judge Clemente did not acknowledge or act on this notice. No response was received.
- Chief Justice Stuart Rabner, 25 Market Street, Trenton, NJ 08625, July 30, 2025: I sent a copy of the Judicial Notice for Disqualification. Chief Justice Rabner did not contact me or take action. No response was received.
- Administrative Office of Court, Honorable Glen A. Grant, 25 Market Street, 7th Fl., Trenton, NJ 08625, July 30, 2025: I sent a copy of the Judicial Notice for Disqualification. Judge Grant did not contact me or take action. No response was received.
- U.S. Department of Justice, 950 Pennsylvania Avenue NW, Washington, DC 20530, July 30, 2025: I sent a copy of the Judicial Notice for Disqualification. The DOJ did not contact me or take action. No response was received.
- Glen Ridge Municipal Court, Attn: Denise C. Landolol, August 5, 2025: I sent an Answer/Demurrer, Affirmative Defense, and Motion. Clerk Landolol did not acknowledge or process my filings. No response was received.
- Glen Ridge Municipal Court, Attn: Denise C. Landolol, September 5, 2025: I sent an OPRA request for the judge’s and prosecutor’s oaths of office and bonds, a tort claim, a demand to dismiss the warrant, and a notice of an account opened in my name for the $500 warrant and two $55 tickets. Clerk Landolol did not provide the requested documents or address my filings. No response was received.
- Essex County Courthouse, Attn: Samantha J. Mendenhall, Presiding Judge, 50 West Market Street, Newark, NJ 07102, September 5, 2025: I sent documents, an OPRA request, and a copy of Judge Clemente’s letter from July 29, 2025. Judge Mendenhall did not contact me or take action. No response was received.
- Glen Ridge Police Department, Sgt. Anthony Mazza, September 5, 2025: I sent a notice of a potential federal civil lawsuit. Sgt. Mazza did not contact me or respond. No response was received.
- Glen Ridge Police Department, Detective Sgt. Daniel Manley, September 27, 2025: I sent a notice of a potential federal civil lawsuit. Sgt. Manley did not contact me or respond. No response was received.
- Glen Ridge Police Department, Lt. Timothy P. Faranda, September 27, 2025: I sent a notice of a potential federal civil lawsuit. Lt. Faranda did not contact me or respond. No response was received.
- Glen Ridge Municipal Court, Attn: Denise C. Landolol, September 27, 2025: I sent a notice of a potential federal civil lawsuit. Clerk Landolol did not contact me or respond. No response was received.
- Glen Ridge Municipal Court, Attn: Mark Clemente, Judge, September 27, 2025: I sent a notice of a potential federal civil lawsuit. Judge Clemente did not contact me or respond. No response was received.
- Glen Ridge Municipal Court, Attn: Elizabeth Brewster, Esq., September 27, 2025: I sent a notice of a potential federal civil lawsuit. Prosecutor Brewster did not contact me or respond. No response was received.
- Borough Administrator Michael Zichelli, 3 Herman Street, Glen Ridge, NJ 07028, September 27, 2025: I sent a notice of a potential federal civil lawsuit. Mr. Zichelli did not contact me or respond. No response was received.
- Borough Administrator Deborah Mans (Mayor), 1 Walkers Lane, Glen Ridge, NJ 07028, September 27, 2025: I sent a notice of a potential federal civil lawsuit. Mayor Mans did not contact me or respond. No response was received.
- ECRB Towing, Joe Strollo, September 27, 2025: I sent a notice of a potential federal civil lawsuit. Mr. Strollo did not contact me or respond. No response was received.
- Essex County Prosecutor, Attn: Theodore N. Stephans II, 50 West Market Street, Newark, NJ 07102, September 27, 2025: I sent a letter about the warrant and concerns about the Internal Affairs investigation of Sgt. Mazza, including my rebuttal to the investigation report. Prosecutor Stephans did not contact me or address my concerns. No response was received.
- Office of the Attorney General NJ, Attn: Jennifer Davenport, 25 Market Street, PO Box 112, Trenton, NJ 08625, October 8, 2025: I sent a letter about the incident and investigation. Ms. Davenport did not contact me or take action. No response was received.
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I sent general (non-certified) mail, which I consider informal and non-binding, to the following officials. I have a video recording of myself at the post office mailing these documents on September 5, 2025, as proof of mailing. Due to my limited income from disability, I could not afford to send these via certified mail:
- Assemblywoman Alixon Collazos-Gill, 39 South Fullerton Avenue, Second Floor, Suite 3, Montclair, NJ 07042, September 5, 2025: I sent a letter informing her of the incident and my concerns about the actions of the Glen Ridge Police Department and Municipal Court. She did not contact me or take action. No response was received.
- Congresswoman LaMonica McIver, 60 Park Place, Suite 302, Newark, NJ 07102, September 5, 2025: I sent a letter informing her of the incident and my concerns about the actions of the Glen Ridge Police Department and Municipal Court. She did not contact me or take action. No response was received.
- Congresswoman Mikie Sherrill, 357 South Livingston Avenue, Suite 201, Livingston, NJ 07039, September 5, 2025: I sent a letter informing her of the incident and my concerns about the actions of the Glen Ridge Police Department and Municipal Court. She did not contact me or take action. No response was received.
- Office of the State Comptroller, P.O. Box 024, Trenton, NJ 08625, September 5, 2025: I sent a letter about the incident and my concerns about the actions of the Glen Ridge Municipal Court. The Comptroller did not contact me or take action. No response was received.
- Essex County Courthouse, Attn: Anu Abraham, 50 West Market Street, Newark, NJ 07102, September 5, 2025: I sent documents requesting that she follow up with the presiding judge to investigate the Glen Ridge Municipal Court’s issuance of the warrant and failure to respond to my filings. Ms. Abraham did not contact me or take action. No response was received.
- U.S. Attorney’s Office for the District of New Jersey, Attn: Jnis L. Baldon, Alina Habba, Nicole Taykhman, 970 Broad Street, 7th Floor, Newark, NJ 07102, September 5, 2025: I sent documents requesting that they investigate the Glen Ridge Municipal Court’s issuance of the warrant and the Internal Affairs investigation of Sgt. Mazza, which I believed was biased. They did not contact me or investigate. No response was received.
- New Jersey Division on Civil Rights, 31 Clinton Street, 3rd Floor, Newark, NJ 07102, September 5, 2025: I sent documents about the lack of accommodation by Sgt. Mazza and the Glen Ridge Municipal Court’s refusal to provide virtual court access despite my disability. The Division did not contact me or investigate. No response was received.
- Glen Ridge Police Department, Attn: Chief Sean Quinn, September 5, 2025: I sent a letter about my Writ of Replevin and complaint against Sgt. Mazza. Chief Quinn did not contact me or take action. No response was received.
- Civil Rights Division, Attn: Assistant Attorney General Dhillon, U.S. Department of Justice, 950 Pennsylvania Avenue NW, Washington, DC 20530, September 5, 2025: I sent documents about the lack of accommodation by Sgt. Mazza and the Glen Ridge Municipal Court’s refusal to provide virtual court access. The Division did not contact me or investigate. No response was received.
- Office of Public Integrity and Accountability, Division of Criminal Justice, 25 Market Street, P.O. Box 085, Trenton, NJ 08625, September 5, 2025: I sent documents about the lack of accommodation by Sgt. Mazza and the Glen Ridge Municipal Court’s actions. The Office did not contact me or investigate. No response was received.
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I learned of the warrant issued by the Glen Ridge Municipal Court through an email from Lt. Timothy P. Faranda, not through formal service by a sheriff, certified mail, or lawful process server. I verified the warrant’s issuance by creating an online account with the Municipal Court system.
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The Internal Affairs investigation into Sgt. Mazza, as communicated by Lt. Faranda, stated that Sgt. Mazza followed policy but did not address my specific concerns or submitted documents.
FURTHER AFFIANT SAYETH NAUGHT.
Executed on this 9th day of October, 2025, in the State of New Jersey.
Naomi Johnson, Affiant
Subscribed and sworn to (or affirmed) before me this ___ day of __________, 2025, by Naomi Johnson, who is personally known to me or who has produced _______________________ as identification.
Notary Public
My Commission Expires: __________
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