COUNTS OF VIOLATION

 

COUNTS OF VIOLATION

FIRST COUNT – Unlawful Stop and Seizure / Violation of Due Process (42 U.S.C. § 1983)
Against: Sergeant Anthony Mazza and Glen Ridge Police Department

144. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

145. On February 24, 2025, Defendant Sergeant Anthony Mazza, acting under color of law, stopped and seized Plaintiff Naomi Johnson’s personal conveyance without probable cause, reasonable suspicion, or judicial authorization, violating her rights under the Fourth, Fifth, and Fourteenth Amendments to the United States Constitution, and corresponding provisions of the New Jersey Constitution, Article I, §§ 1, 7, 18.

146. Defendants’ acts constitute an abuse of authority, deprivation of liberty, and unlawful interference with property, in violation of Blackstone’s Commentaries on the Laws of England, Am. Jur. 2d § 14, and the maxim “Nullum crimen sine lege, nulla poena sine lege” (no crime or penalty without law).

147. The stop and seizure occurred despite Plaintiff providing valid identification and registration; she was forced to submit to questioning without explanation, and her conveyance was towed without her consent or judicial order.

148. Plaintiff was denied procedural due process, including notice, opportunity to contest the seizure, and accommodations for her disability, in violation of Title II of the Americans with Disabilities Act (42 U.S.C. § 12131 et seq.), New Jersey Law Against Discrimination (N.J.S.A. 10:5-1 et seq.), and the Preamble to the U.S. Constitution guaranteeing liberty and justice.

149. As a direct result of Defendants’ conduct, Plaintiff suffered loss of property, deprivation of freedom of movement, emotional distress, and financial harm.

SECOND COUNT – Unauthorized Towing / Conversion of Property / Theft
Against: E.C.R.B. Towing & Recovery and Joe Strollo

150. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

151. Defendant E.C.R.B. Towing & Recovery, acting in coordination with Glen Ridge Police Department, seized Plaintiff’s conveyance without her consent, without judicial authorization, and imposed excessive fees in violation of the New Jersey Predatory Towing Prevention Act, Glen Ridge Borough Ordinances Chapter 10-05, and New Jersey common law principles of conversion and trespass.

152. The Defendants’ conduct constitutes theft under NJSA 2C:20-3, misappropriation of property, and abuse of legal process, violating the Due Process Clause of the Fifth and Fourteenth Amendments.

153. Plaintiff’s vehicle displayed a handicap plate; Defendants ignored her disability, creating unnecessary physical and financial hardship, in violation of Title II of the ADA (42 U.S.C. § 12131 et seq.) and 42 U.S.C. § 1983.

154. Defendants charged storage, hook, yard, and “abandonment notice” fees prematurely, and failed to provide lawful access to Plaintiff, demonstrating deliberate disregard for statutory requirements and her unalienable property rights as guaranteed under the Declaration of Independence and natural law principles.

155. Plaintiff has suffered financial loss, deprivation of property, emotional distress, and interference with her rights to mobility and autonomy.

THIRD COUNT – ADA / Disability Rights Violations
Against: Glen Ridge Police Department, Municipal Court, and E.C.R.B. Towing & Recovery

156. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

157. Defendants failed to provide reasonable accommodations to Plaintiff, a medically disabled woman, denying her access to government services and programs, in violation of Title II of the Americans with Disabilities Act (42 U.S.C. § 12131 et seq.), the ADA Amendments Act, and New Jersey disability access laws.

158. Defendants’ refusal to accommodate Plaintiff’s mobility needs, including towing her handicap-designated vehicle and requiring in-person court appearance at a non-accessible location, caused undue physical, emotional, and financial hardship.

159. These actions violate 42 U.S.C. § 1983, Article I, §§ 1, 7, 18 of the New Jersey Constitution, and civil liberties recognized under the Universal Declaration of Human Rights (Articles 3 and 17) and the preamble to the U.S. Constitution (“secure the Blessings of Liberty to ourselves and our Posterity”).

160. Plaintiff has suffered and continues to suffer harm, including restricted mobility, deprivation of independence, emotional distress, and financial injury.

FOURTH COUNT – Due Process / Procedural Violations
Against: Glen Ridge Municipal Court, Judge Mark Clemente, Administrative Court Clerk Denise Iandolo, and Borough Prosecutor Elizabeth Brewster

161. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

162. Defendants denied Plaintiff her constitutional rights to notice, hearing, and opportunity to be heard under the Fifth, Sixth, and Fourteenth Amendments, violating due process, equal protection, and civil liberties recognized under natural law and Am. Jur. 2d § 72.

163. Defendants issued a bench warrant without notice, refused to respond to motions to dismiss or challenge jurisdiction, and ignored Plaintiff’s Writs of Replevin, Notice of Default, and True Bills, thereby depriving her of lawful remedy.

164. Defendants’ conduct constitutes abuse of process, misapplication of statutes, conversion of property interests, and coercion under threat of arrest, in violation of Blackstone, the Supremacy Clause (U.S. Const. Art. VI, cl. 2), and Am. Jur. 2d §§ 14, 17.

165. As a direct result of these actions, Plaintiff has suffered financial harm, emotional distress, and ongoing deprivation of liberty and constitutional rights.

If this structure and legal grounding meet your expectations, I can continue with Counts 5–14, ensuring each count references:

• Federal and state law (e.g., 42 U.S.C. § 1981, § 1983, Title II ADA, NJ Predatory Towing Act)

• Constitutional protections (Bill of Rights, Supremacy Clause, NJ Constitution)

• Historical authorities and legal maxims (Blackstone, Am. Jurisprudence, Declaration of Independence, NOS 440)

• Civil, human, and property rights principles

• Biblical or moral authority references where appropriate for rhetoric and persuasive emphasis

FIFTH COUNT – Unlawful Seizure / Theft / Predatory Towing
Against: E.C.R.B. Towing & Recovery and Glen Ridge Police Department

166. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

167. Defendants unlawfully seized Plaintiff’s private conveyance without her consent, without judicial authorization, and imposed excessive towing and storage fees in violation of New Jersey Predatory Towing Prevention Act, Glen Ridge Borough Ordinances Chapter 10-05, and common law principles of conversion and theft.

168. Defendants’ acts constitute theft by deception, misappropriation, and deprivation of property in violation of 42 U.S.C. § 1983, NJSA 2C:20-3, and the Due Process Clause of the Fifth and Fourteenth Amendments.

169. Plaintiff was denied access to her vehicle despite displaying a handicap plate; Defendants ignored her disability and failed to provide reasonable accommodations, violating Title II of the ADA (42 U.S.C. § 12131 et seq.).

170. As a direct result, Plaintiff suffered financial loss, deprivation of property, emotional distress, and interference with her constitutional and civil rights.

SIXTH COUNT – ADA / Disability Rights Violations
Against: Glen Ridge Police Department, Municipal Court, and E.C.R.B. Towing & Recovery

171. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

172. Defendants denied Plaintiff reasonable accommodations as a disabled individual, violating Title II of the Americans with Disabilities Act (42 U.S.C. § 12131 et seq.), ADA Amendments Act, and New Jersey disability access protections.

173. Defendants’ failure to provide accommodations—including towing her handicap-designated vehicle, charging excessive fees, and requiring inaccessible in-person court appearances—caused undue physical, financial, and emotional hardship.

174. Defendants’ actions violate 42 U.S.C. § 1983, natural law principles, Am. Jur. 2d § 14, and Plaintiff’s unalienable rights under the Declaration of Independence.

175. As a direct result, Plaintiff suffered deprivation of mobility, interference with her independence, financial loss, and emotional distress.

SEVENTH COUNT – Due Process and Constitutional Violations
Against: Glen Ridge Police Department, Municipal Court, and associated officials

176. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

177. Defendants deprived Plaintiff of constitutional rights, including due process, equal protection, and the right to confront her accuser, under the Fifth, Sixth, and Fourteenth Amendments, and corresponding provisions of the New Jersey Constitution.

178. Defendants issued a bench warrant without proper notice, ignored motions challenging jurisdiction, and failed to provide cause of action or proof of claim, violating 42 U.S.C. § 1983, Am. Jur. 2d §§ 72, 93, and civil law maxims regarding presumption of law versus evidence.

179. Defendants’ coordinated actions with the towing company demonstrate willful interference with Plaintiff’s property, liberty, and civil rights.

180. As a result, Plaintiff suffered continued threat of arrest, emotional distress, financial injury, and deprivation of constitutional rights.

EIGHTH COUNT – Theft, Conversion, and Misappropriation of Property
Against: E.C.R.B. Towing & Recovery, Glen Ridge Police Department, and Municipal Court officials

181. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

182. Defendants unlawfully seized, retained, and profited from Plaintiff’s personal conveyance without consent, judicial authorization, or lawful fees, constituting theft, conversion, and misappropriation under NJ law, Am. Jur. 2d, and civil law principles.

183. Defendants’ acts violate 42 U.S.C. § 1983, NJSA 2C:20-3, Due Process Clause, and unalienable property rights under the Declaration of Independence.

184. Plaintiff suffered financial harm, loss of property, emotional distress, and deprivation of civil liberties.

NINTH COUNT – ADA / Disability Rights Violations
Against: Glen Ridge Police, Municipal Court, and E.C.R.B. Towing

185. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

186. Plaintiff was denied reasonable accommodations during the unlawful stop, seizure, and towing of her conveyance, violating Title II of the ADA (42 U.S.C. § 12131 et seq.) and New Jersey disability protections.

187. Defendants’ refusal to accommodate Plaintiff, including denying remote court appearances and ignoring her handicap designation on the vehicle, caused physical, financial, and emotional hardship.

188. Plaintiff’s rights to independent mobility, access to services, and personal safety were directly impeded, in violation of civil rights, natural law, and legal maxims protecting liberty and property.

TENTH COUNT – Due Process Violations
Against: Glen Ridge Police Department, Municipal Court, and associated officials

189. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

190. Defendants denied Plaintiff notice, opportunity to be heard, and the ability to contest charges, violating Fifth and Fourteenth Amendment protections, NJ Constitution Article I, §§ 1, 7, 18, and principles of natural justice recognized in Blackstone and Am. Jur. 2d.

191. Defendants issued bench warrants without proper notice, ignored Plaintiff’s filings, and coerced compliance under threat of arrest, constituting abuse of process, misapplication of law, and deprivation of civil liberties.

192. Plaintiff suffered emotional distress, financial harm, ongoing legal jeopardy, and restriction of personal liberty.

ELEVENTH COUNT – Unlawful Seizure / Theft / Conversion of Property
Against: Sgt. Anthony Mazza, E.C.R.B. Towing, and Glen Ridge Municipal Court

193. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

194. Plaintiff’s conveyance was seized and held without consent, judicial authorization, or lawful fees, constituting conversion, theft, and misappropriation of property.

195. Actions by Defendants violated NJ law, 42 U.S.C. § 1983, constitutional due process, and civil rights doctrines.

196. Plaintiff suffered ongoing deprivation of liberty, interference with property rights, financial harm, and emotional distress.

TWELFTH COUNT – Unauthorized Account Creation / Deprivation of Property / Misuse of Judicial Authority
Against: Glen Ridge Municipal Court, Judge, Prosecutor, and Administrative Court Clerk

197. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

198. On February 24, 2025, Defendants imposed a $500 warrant in Plaintiff’s name without consent, lawful notice, or authority, creating an unauthorized account or liability in violation of due process (Fifth and Fourteenth Amendments), NJ Constitution, and natural law.

199. Defendants’ acts constitute abuse of process, conversion, trespass, and misapplication of statutes, resulting in deprivation of property, financial harm, and violation of fiduciary duties.

THIRTEENTH COUNT – Racial Profiling and Equal Protection Violations
Against: Glen Ridge Police Department, Municipal Court, and Township authorities

200. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

201. Plaintiff’s race was recorded on the traffic citation without legitimate law enforcement purpose, creating a risk of discriminatory treatment and racial profiling in violation of the Equal Protection Clause (Fourteenth Amendment), 42 U.S.C. §§ 1981 and 1983, Title VI of the Civil Rights Act of 1964, and N.J.S.A. 10:5-1 et seq.

202. Defendants’ actions exposed Plaintiff to disparate treatment, emotional distress, and deprivation of civil rights.

FOURTEENTH COUNT – Deprivation of Property / Trespass Under Color of Law
Against: E.C.R.B. Towing & Recovery, Sgt. Anthony Mazza, and Glen Ridge Police Department

203. Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.

204. Plaintiff’s conveyance was seized, impounded, and held without judicial authorization, consent, or lawful authority, constituting trespass, conversion, and violation of 42 U.S.C. § 1983.

205. Defendants acted under color of law, misapplied statutes, and deprived Plaintiff of property and civil liberties, resulting in financial loss, emotional distress, and interference with her rights.