NOTICE OF NEWLY DISCOVERED MATERIAL EVIDENCE – SECURE EVIDENCE LINK ENCLOSED

 Naomi Johnson 

PO BOX 202

Glen Ridge, New Jersey 07028


Complainant

December 4, 2025


Assistant Prosecutor Steven Paskowitz 

Professional Standards Bureau 

Essex County Prosecutor’s Office 

50 West Market Street Newark, NJ 07102

Re: PSB Case #2025-310 / Glen Ridge PD Case #2025-005 NOTICE OF NEWLY DISCOVERED MATERIAL EVIDENCE – SECURE EVIDENCE LINK ENCLOSED

Dear Assistant Prosecutor Paskowitz,

Enclosed please find my formal Notice of Newly Discovered Material Evidence Requiring Immediate Reconsideration (with Declaration). Due to the volume of video and documentary evidence, and to avoid excessive mailing costs, all exhibits and the complete body-worn/in-car camera footage have been placed in a single, password-protected folder that is accessible only to the recipients of this letter.

Secure Evidence Link have 19 evidences: https://u.pcloud.link/publink/show?code=VZj3aP5ZNzlkS7vGvwfazXczROLJEf1DbP5V and https://u.pcloud.link/publink/show?code=VZDNaP5ZodpYHdkDJ1jUBzlEzuxpKV7ku8rX

 The folder contains clearly labeled files, including:

    • Towing receipt proving the stop and impoundment occurred in Montclair 

    • Body-worn camera footage and transcript (edited key segments + full raw file) 

    • CAD report, incomplete Tow Report, violated SOPs, medical documentation, etc. 

These materials were not provided with my original submission and conclusively establish multiple criminal and serious administrative violations by Sgt. Anthony Mazza.

Please confirm receipt and immediate action within five (5) business days. The 20-day demand clock in the enclosed Notice begins running upon your receipt of this letter.

Thank you for your prompt attention to this serious matter of public corruption and civil-rights deprivation.


Respectfully,


Naomi Johnson 

Without Prejudice/All Rights Reserved 

Enclosures:

    1. Notice of Newly Discovered Material Evidence (with Declaration) 

    2. This Cover Letter (containing secure link and password) 

CC (via First-Class Mail):

    • Theodore N. Stephens II, Essex County Prosecutor 

    • Romesh Sukhdeo, First Assistant Prosecutor 

    • Mitchell G. McGuire III, Chief of County Detectives 

    • Attorney General Matthew Platkin 

    • Director, Office of Public Integrity & Accountability 

    • Glen Ridge Borough Clerk




Naomi Johnson 

20 Glen Ridge Avenue

Montclair, Nee Jersey 07042

noneillah@gmail.com

0r

PO BOX 202

Glen Ridge, New Jersey 07028


December 4, 2025

VIA CERTIFIED MAIL – RETURN RECEIPT REQUESTED and EMAIL 

Assistant Prosecutor Steven Paskowitz 

Professional Standards Bureau Essex County Prosecutor’s Office 

50 West Market Street Newark, NJ 07102


Re: PSB Case #2025-310 / 

Glen Ridge PD Case #2025-005 

NOTICE OF NEWLY DISCOVERED MATERIAL EVIDENCE REQUIRING IMMEDIATE RECONSIDERATION OF CRIMINAL DECLINATION AND DIRECT PROSECUTORIAL SUPERVISION OF ADMINISTRATIVE INVESTIGATION

DEMAND PURSUANT TO ATTORNEY GENERAL INTERNAL AFFAIRS POLICY & PROCEDURES

Dear Assistant Prosecutor Paskowitz,

On or about September 27, 2025, I provided your office with evidence of serious police misconduct committed by Glen Ridge Police Sergeant Anthony Mazza on February 24, 2025 incident in Montclair, New Jersey. Your subsequent letter to Lt. Faranda concluded there was “insufficient credible evidence” to warrant criminal prosecution and referred the matter back to the Glen Ridge Police Department for administrative action.

I am now in possession of newly discovered, dispositive evidence that was not provided to you. This evidence directly contradicts the limited record you reviewed and proves multiple criminal and serious administrative violations by Sgt. Mazza.

The following documents are attached as exhibits:

    1. Towing receipt from E.C.R.B clearly stating my vehicle was towed from Montclair, NJ – proving Sgt. Mazza falsified the location of the stop on official citations (N.J.S.A. 2C:28-7, 2C:21-4, 2C:30-2).

    2. CAD report conflict time of call: 15:28, dispatched: 15:29, arrived: 15:28, cleared:15:53, time on scene 00:28 and body-worn camera footage showing the stop occurred entirely in Montclair. Also, the video transcript.

    3. Incomplete Glen Ridge PD Towing Report (no consent, no tow operator name, no receipt provided).

    4. Glen Ridge Police Department Standard Operating Procedures – Motor Vehicle Impound & Inventory and Traffic Enforcement & Control – explicitly violated by Sgt. Mazza.

    5. Picture of handicap placard “HV” noted on citation and image of spoiled food left in my conveyance for seven days while in the impound.

    6. Proof no mutual-aid or interlocal agreement exists authorizing Glen Ridge officers to conduct traffic enforcement in Montclair and more.

Under the Attorney General’s Internal Affairs Policy & Procedures (rev. Nov. 2022) you are required to:

    • § 1.0.6 & § 6.3.2: Exercise direct supervision over investigations involving potential criminal conduct

    • § 7.2.2: Retrieve and review all video, electronic, and documentary evidence

    • § 6.3.8: Continue administrative investigation under preponderance standard even after criminal declination

    • § 1.0.5: Ensure subordinate agencies (Glen Ridge PD) comply with IAPP – which they have repeatedly failed to do

Returning this matter to the same agency that has already refused to open a proper internal affairs file, ignored my complaints to Chief Sean Quinn and Det. Sgt. Daniel Manley, and produced a demonstrably false report by Lt. Faranda creates an irreconcilable conflict and defeats the entire purpose of prosecutorial oversight.

DEMAND (20 days from receipt)

    1. Immediately reopen PSB #2025-310 and supplement the file with the attached evidence

    2. Personally direct or assign an independent investigator (outside Glen Ridge PD) to conduct a full administrative internal affairs investigation

    3. Issue written confirmation that the unlawful $500 bench warrant stemming from void citations will be vacated

    4. Provide written acknowledgment of receipt and your intended course of action

Failure to act will leave me no choice but to escalate this matter to Acting Prosecutor Theodore N. Stephens II, the Attorney General’s Office of Public Integrity & Accountability, the Division on Civil Rights, and federal oversight authorities, and to seek appropriate relief in my pending federal civil rights litigation.

A courtesy copy of this Notice is being sent to:

    • Romesh Sukhdeo, First Assistant Prosecutor

    • Mitchell G. McGuire III, Chief of County Detectives

    • Theodore N. Stephens II, Essex County Prosecutor

    • Matthew Platkin, New Jersey Attorney General

    • Director, Office of Public Integrity & Accountability

    • Glen Ridge Borough Clerk (for public record)

Respectfully,


Naomi Johnson 

Without Prejudice/All Rights Reserve

Enclosures: Exhibits 1–8 + Declaration (below)

CC (via certified mail): 

Romesh Sukhdeo, First Assistant Prosecutor 

Mitchell G. McGuire III, Chief of County Detectives

Theodore N. Stephens II, Essex County Prosecutor Attorney

General Matthew Platkin Office of Public Integrity & Accountability Glen Ridge Borough Clerk

DECLARATION OF NAOMI JOHNSON (28 U.S.C. § 1746 / N.J.S.A. 2A:162-2)

I, Naomi Johnson, declare under penalty of perjury:

    1. I am the complainant in the above-referenced matter.

    2. The facts stated in the foregoing Notice are true and correct to my own knowledge except as to matters stated on information and belief, and as to those matters I believe them to be true.

    3. The exhibits attached to the Notice are true the best of my knowledge and correct copies of the originals in my possession.

Executed on December 4, 2025


Naomi Johnson

Naomi Johnson – One of the People of New Jersey

Public Notice of 21 Acts of Trespass and Official Misconduct Committed by Glen Ridge Police Sergeant Anthony Mazza

To every public servant who took an oath to the New Jersey and United States Constitutions: You are hereby put on notice of the following twenty-one (21) deliberate trespasses committed against my person, my property, and my unalienable rights.

    1. Extraterritorial stop in Montclair, New Jersey with zero jurisdiction and zero mutual-aid agreement, violation of State v. Scotus, 114 N.J. 327 (1989) and AG Directive 2021-6. 

    2. Random license-plate run with no reasonable articulable suspicion of any crime whatsoever,  violation of the 4th & 14th Amendments (Delaware v. Prouse, 440 U.S. 648 (1979)). 

    3. Activated silent emergency lights to force me to stop, N.J.S.A. 39:4-91 only authorizes lights + audible siren for actual emergencies or pursuit, not minor traffic infractions. 

    4. Lied and told me the stop was based on “probable cause”, a legal term reserved for crimes only. 

    5. When I asked if I had committed a crime, he falsely stated “the crime is a motor vehicle infraction”, deliberate misapplication of law. 

    6. Walked in front of my vehicle and invented a new reason (“no inspection sticker”) that was physically impossible to observe from behind, another proven lie. 

    7. Ordered my private conveyance towed from Montclair, a town in which he has zero lawful authority, without warrant, without consent, without exigent circumstances. 

    8. Conspiracy with the tow company to steal my private property under color of law. 

    9. Knew from my handicap placard that I am disabled, yet forced me to walk miles home, deliberate ADA Title II violation of Federal law. 

    10. Failed to ensure my safety or offer any aid as required of every public servant and by department SOP. 

    11. Falsely documented the stop location as “Glen Ridge” on both tickets and reports when dispatch audio and tow receipt prove it happened in Montclair, falsification of government records. 

    12. Left the tow report completely blank: no tow-driver name, no inventory, no consent, no copy given to me the day of incident, direct violation of Glen Ridge PD Impound & Inventory SOP. 

    13. Conducted the entire impoundment with no judicial warrant whatsoever. 

    14. My groceries and personal property were left to rot for seven full days because I had no way to retrieve my vehicle. 

    15. Crossed municipal boundaries for a minor-traffic enforcement with no mutual-aid request or agreement with Montclair or Essex County. 

    16. Misbranded a civil motor-vehicle infraction as a “crime”,  intentional misrepresentation of law. 

    17. Issued two $55 citations in a town where he had no jurisdiction. 

    18. Marked “B” (Black) on the citation with no law-enforcement purpose, prima-facie evidence of racial designation and profiling (NJ Law Against Discrimination & AG Directive 2021-6). 

    19. Repeatedly lied directly to my face about the law, the reason for the stop, and my rights. 

    20. Violated my Americans with Disabilities Act rights, my 4th Amendment right against unreasonable seizure, my 14th Amendment due-process rights, and racially profiled me. 

    21. Every act above was an unauthorized exercise of his office, knowing it was unauthorized, for the purpose of injuring me and depriving me of my property and liberty, the textbook definition of Official Misconduct under N.J.S.A. 2C:30-2(a). 

These 21 acts are not mere “mistakes.” They are deliberate, willful, and repeated trespasses by a public servant who has forgotten that he is a trustee of the People, not our master.

Under the Attorney General’s Internal Affairs Policy & Procedures and AG Directive 2021-6, each of these 21 violations must be classified as SUSTAINED by a preponderance of the evidence. Each should trigger major disciplinary action, up to and including termination, with mandatory public reporting by name. All 21 violations should also be added to the Brady/Giglio list.

I demand full accountability on all 21 counts, no merging, no minimizing, no “officer discretion” excuses.

In liberty and without retreat,

Naomi Johnson

One of the People of New Jersey

December 4, 2025



Naomi Johnson – One of the People of New Jersey Public Notice of Trespass – Amended and Expanded to 23 Counts (Every violation now includes the unlawful warrant and alleged judicial extortion)

To:

    • Chief of Police, Glen Ridge Borough 

    • Theodore N. Stephens II, Essex County Prosecutor 

    • Matthew J. Platkin, Attorney General of New Jersey 

    • Office of Public Integrity & Accountability (OPIA) 

    • All other public servants who took an oath 

I am adding two more deliberate trespasses to the original 21, bringing the total to twenty-three (23) distinct acts of official misconduct, constitutional violations, and outright criminal extortion committed against me by Sgt. Anthony Mazza and by the Glen Ridge Municipal Court (Judge Mark Clemente) acting in conspiracy with this lawless behavior.

22. Issuance of an Unlawful $550 Bench Warrant with Black/African American for “Failure to Appear” on Two Title 39 Traffic Summonses The two $55 tickets were issued in Montclair, a town where Glen Ridge police have zero jurisdiction and zero mutual-aid agreement. Because the underlying tickets are void ab initio (State v. Scotus, 114 N.J. 327 (1989)), the Glen Ridge Municipal Court has no subject-matter jurisdiction over those summonses. Yet the court issued a bench warrant threatening my arrest and demanding $550 cash bail/bond to lift it. This is a blatant violation of:

    • Eighth Amendment (excessive fines/bail prohibited, even for criminal cases, certainly prohibited for civil Title 39 matters) 

    • State v. Scotus, 114 N.J. 327 (1989), municipal courts have no authority to issue criminal arrest warrants for Title 39 violations or simple failure to appear 

    • N.J.S.A. 2B:12-16 – municipal court jurisdiction is limited to the municipality’s geographic borders 

    • N.J. Court Directive #04-20 (issued by the Administrative Office of the Courts), explicitly prohibits the issuance of criminal bench warrants for Title 39 failure-to-appear cases This warrant is void on its face and constitutes false imprisonment under color of law. 

23.Judicial Extortion Under Color of Law (N.J.S.A. 2C:20-5 & 2C:30-2)

It is alleged that Municipal Court Judge Mark Clemente, in his official capacity, demanded that I, a private citizen domiciled in New Jersey, pay $550 (or face arrest) for two traffic citations. These citations were issued outside the township’s jurisdiction, are believed to be void, and do not require a mandatory court appearance, as they are payable summonses.

Using the threat of arrest or imprisonment to collect payment for obligations that may not lawfully exist raises serious concerns under New Jersey law. If substantiated, this conduct could constitute official misconduct (N.J.S.A. 2C:30-2) and theft by extortion (N.J.S.A. 2C:20-5) under color of judicial office.


Bench Warrant and Traffic Citation Concerns – Glen Ridge Municipal Court

Race or ethnicity should not be included on a Glen Ridge Municipal Court bench warrant, or on any New Jersey municipal bench warrant, for a minor traffic matter. Bench warrants are administrative tools issued for non-compliance (e.g., failure to appear or failure to pay a fine) and follow strict procedural rules that do not require or authorize demographic notations such as race or ethnicity.

Under New Jersey Court Rule 3:2-3 (Arrest Warrant), a warrant must include the signature of the issuing judicial officer (judge or clerk) but does not permit or require race or other personal descriptors.

The New Jersey Supreme Court directive issued in 2022 reformed municipal court bench warrant practices to emphasize equity and reduce unnecessary arrests for low-level offenses, such as traffic fines. The directive encourages release without bail for most Title 39 failures-to-appear and makes no mention of race as a required or permitted field.

Warrants processed electronically via the Judiciary’s PROMIS/Gavel system include basic identifiers, name, date of birth, address, and offense details only. It exclude race in order to prevent biased enforcement.”

It appears improper for the court to require online payment of two traffic citations totaling $55 while simultaneously maintaining a $500 warrant arising from the same matter. Because Title 39 violations are civil in nature, the imposition of a high warrant amount and the threat of arrest may constitute an excessive or coercive bail practice.


I am requesting, as part of your investigatory responsibilities, clarification regarding: 

(1) the basis for the warrant,

(2) the court’s authority to impose such bail on a civil infraction, and

(3) the legal justification for threatening arrest in connection with a minor Title 39 matter.

Based on the New Jersey Internal Affairs Policy & Procedures, “…I request that Internal Affairs assess whether these actions potentially violate applicable policies governing fairness, proper warrant issuance, or misuse of authority.”




Clear Statement to the Attorney General and County Prosecutor

The Attorney General’s Internal Affairs Policy & Procedures (IAPP §§ 1.0.6, 6.3.2, and 9.10) and AG Directive 2021-6 mandate that:

    • Any allegation of criminal conduct by a police officer or a judicial officer must be immediately forwarded to the County Prosecutor (and, when appropriate, directly to OPIA). 

    • The Prosecutor shall not defer or decline investigation simply because the police department is “handling it administratively.” 

    • Any false reports, official misconduct, extortion, and civil rights violations under color of law are, first and foremost, criminal matters. Administrative or internal affairs processes are secondary and cannot replace proper criminal investigation or prosecution. I am requesting that these matters be referred to the appropriate criminal investigative and prosecutorial authorities for full review and action.

Based on the evidence in my possession, I have now documented twenty-three (23) alleged violations of criminal law, civil rights law, and constitutional due-process, including but not limited to:

• Official Misconduct (N.J.S.A. 2C:30-2) – alleged abuse of official authority in the initiation and handling of the citation, warrant, and related actions.

• Falsification or improper creation of governmental records – including alleged inaccuracies or irregularities in the citation, warrant, and administrative processing.

• Theft by extortion – alleging that municipal personnel and judge demanded or attempted to collect money through legal processes that should be void or unsupported by law.

    •  Violations of civil rights under color of law

(42 U.S.C. § 1983; N.J.S.A. 10:6-2) – including due-process violations, alleged unlawful seizure, and deprivation of rights secured under the Constitution and state law.

      

    • Conspiracy between police officer and municipal court judge to collect money on void process 

    • • Possible conspiracy between certain police personnel and municipal court personnel – based on communications, actions, or patterns suggesting coordinated efforts to enforce or collect on legal process that I believe to be defective.

These issues, taken together, appear to exceed the scope of routine Internal Affairs review, and may require referral to the appropriate criminal, oversight, or supervisory units, including but not limited to the County Prosecutor’s Office, Professional Responsibility Unit, and any internal Financial Integrity/Anti-Corruption unit.

My Lawful Demand (under penalty of perjury)

       

    1. That the Glen Ridge Police Department complete its Internal Affairs investigation and determine whether the 23 allegations against Sgt. Mazza should be sustained, and that the full investigative file be forwarded to the Essex County Prosecutor’s Office for review.

    2. That the Essex County Prosecutor’s Office conduct an independent review of the conduct of Sgt. Mazza and of the actions taken by the Glen Ridge Municipal Court to determine whether any elements of official misconduct or improper financial practices may be implicated.

    3. “I did not pay the $55 ticket or the $500 warrant. However, I am requesting a complete accounting of any fees, assessments, surcharges, or financial entries that may have been generated in my name as a result of these actions. If any improper charges, automatic assessments, or administrative financial entries were created, I request that they be identified, reversed, and refunded to me through the appropriate legal process.”

    4. That, if the investigation substantiates serious misconduct, major discipline, up to and including termination, be imposed and publicly reported by name pursuant to AG Directive 2021-6.


These matters raise serious concerns about the proper exercise of authority and the treatment I received.

I am submitting this in good faith as a private individual domiciled in New Jersey, seeking accountability consistent with the Constitution, state law, and the Attorney General’s Internal Affairs Policy & Procedures.

       

The Internal Affairs Policy & Procedures, which every agency in New Jersey is required to follow, demands that the following charges be SUSTAINED by a preponderance of the evidence (the much lower standard that applies to administrative discipline):

      

    • Extraterritorial Enforcement Without Jurisdiction 

    • Racial Profiling / Differential Treatment (IAPP §2.2.2(f)) (The standard New Jersey Uniform Traffic Ticket (UTT) form, used statewide for minor violations, does not include a field for race or ethnicity. Officers are trained to omit such information). In my case, it is not standard procedure. Sgt. Mazza's citation, the "B" notation appears to violate these anti-profiling standards, especially combined with the extraterritorial stop and other irregularities I described in this letter.

    • Americans with Disabilities Act Violation (Federal law) 

    • Fourth Amendment Unreasonable Seizure 

    • Theft Under Color of Law / Conspiracy to Deprive Property 

    • Conduct Unbecoming a Public Servant 

    • Neglect of Duty / Failure to Follow SOPs 

Under AG Directive 2021-6 (Major Discipline), any sustained finding in the above categories triggers mandatory public reporting by name, including termination, demotion, or suspension greater than five days.

“I request that the Essex County Prosecutor’s Office take the following actions consistent with the New Jersey Attorney General’s Internal Affairs Policy & Procedures:

    1. Sustain each substantiated allegation identified through the Internal Affairs investigation;

    2. Pursue major discipline, up to and including termination, as permitted under the AG guidelines for serious misconduct;

    3. Formally review Sgt. Mazza for potential criminal official misconduct and, if supported by the evidence, initiate referral and charging decisions;

    4. Evaluate whether Sgt. Mazza must be added to the Brady/Giglio disclosure list, due to conduct that may impair his credibility in future prosecutions;

    5. Review the lawfulness of the tickets issued in this incident and, if improper, pursue the appropriate legal mechanism to vacate them and ensure that any payments made under alleged coercive circumstances are corrected or refunded;

    6. Publicly report any final discipline by name, as required by law.

These requests are made in good faith and are based on my understanding of your office’s statutory and constitutional obligations.”

“I am a private individual domiciled in New Jersey, exercising my rights under the New Jersey and United States Constitutions. As a private citizen, I expect public officials to uphold their constitutional obligations and the public trust consistent with their oath of office. My concerns relate to whether proper authority, procedure, and constitutional protections were followed in this matter.”

I am submitting this notice to request correction of the issues described. If these matters are not addressed within ten (10) days, I will proceed with filing formal complaints with the Office of Public Integrity & Accountability (OPIA), the FBI Civil Rights Unit, and the New Jersey Advisory Committee on Judicial Conduct, as appropriate.

This is a civil Title 39 matter. I object to being treated as though I am facing criminal charges, and I object to any processes or demands that appear inconsistent with constitutional or statutory authority.

I expect all involved officials to act in accordance with law, policy, and their oath of office.

Respectfully,


Naomi Johnson

Private Citizen domiciled in New Jersey

December 4, 2025


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