AFFIDAVIT OF COMPLAINT AND DECLARATION OF COMPLAINT AGAINST GLEN RIDGE POLICE AND E.C.R.B. TOWING & RECOVERY
AFFIDAVIT OF COMPLAINT
State of New Jersey
County of ESSEX
I, Naomi Johnson, mailing address prevision 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: regulations governing contractors engaged in the removal of motor vehicles, towing services, road services and towing of vehicles that are abandoned, disabled, illegally parked, recovered stolen, involved in motor vehicle crashes and/or suspected or identified by the borough as being involved in criminal activities
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 (i.e., it was not abandoned, illegally parked, blocking traffic, part of a criminal investigation, or involved in an accident).
(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, charges, or the reason for the tow before hand. I received the receipt of the breakage of pay when I picked it up my car from the towing company.
(C) Charging Excessive or Unauthorized Fees (N.J.S.A. 56:13-16)
• E.C.R.B. Towing attempted to charge me an abandonment notice fee and threatened to claim my vehicle title before the legal time frame of 15-30 days.
• This was a fraudulent charge in an attempt to seize ownership of my vehicle unlawfully.
(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: Monday thru Friday (8 Am-4:30 PM) , Saturday (9 AM-12PM) and closed on Sunday. On E.C.R.B Towing & Recovery business card it states they have 24 hour service. The business card is misleading. It has a person to believe they are open 24 hours., which they are not. It is 24 hour only for towing services.
◦ February 26, 2025 (4:30 PM) – Closed
◦ February 27, 2025 (4:30 PM) – Closed
◦ March 1, 2025 – (12 PM)-Closed, no accommodations made for retrieval.
• Under NJ law, a towing company must have a business office open from 8 AM to 6 PM at least five (5) days a week and provide reasonable after-hours access.
(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 that is their procedure to get the title of the car for vehicle that is abandoned before the legally required which is a 15-day 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 under NJ law.
• The police ethics department took my complaint and falsely stating that the officer “had the right” to tow my vehicle and give me two tickets.
4. Constitutional and Disability Rights Violations
The actions taken against me violated my constitutional and disability rights:
• Fourth Amendment Violation: My vehicle was unlawfully seized without a warrant, probable cause, or legal justification.
• Fourteenth Amendment Violation: I was denied due process, as my property was taken without legal procedure.
• Disability Rights Violations: The loss of my vehicle left me stranded and in physical pain, worsening my pre-existing disability.
• Failure to Provide a Reasonable Modification (28 C.F.R. § 35.130(b)(7).
• Financial Loss: Groceries were left in my car and spoiled over seven days, causing additional financial hardship.
5. Demands for Investigation and Remedies
Given the clear violations of the Predatory Towing Prevention Act, 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, punitive damages and financial losses.
4. Dismissed my two tickets and removed traffic violation points from my driving records.
5. Corrective action against Glen Ridge Police Department for participating in predatory towing practices.
6. Changes to police department policies to prevent further abuse of power regarding vehicle towing.
I submit this affidavit 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 March 8, 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 whose name is subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained.
In witness whereof, I hereunto set my hand and official seal.
Notary Public Signature: ________________________
My Commission Expires: ______________
Naomi Johnson
Glen Ridge , New Jersey 07028
Subject: Formal Complaint Regarding Unlawful Vehicle Towing and Violation of Rights
To Whom It May Concern,
Officer Anthony D. Mazza of the Glen Ridge Police Department Glen Ridge Police Department , Glen Ridge Municipal Court
825 Bloomfield Ave, Glen Ridge, NJ 07028 and E.C.R.B. Towing and Recovery, located at 329 Broad Street, Bloomfield, NJ 07003, conspired to unlawfully seize my vehicle under false pretenses. Officer Mazza stated that he was towing my car because I allegedly drove through a stop sign without stopping. I informed the officer that I did, in fact, stop, look around, and then proceed. However, upon hearing my statement, Officer Mazza changed his claim, now stating that I did not stop at all.
I asked Officer Mazza whether he had articulable reasonable suspicion to pull me over, meaning he suspected me of being involved in a criminal act. He seemed surprised by my knowledge and asked how I knew about that. He then claimed he stopped me under probable cause. I responded by pointing out that probable cause still applies only to criminal acts, but at a higher level of legal scrutiny. In order to detain me for a crime, there must be corpus delicti—which means there must be evidence of a crime, a victim, or an affidavit from an injured party accusing me of committing a criminal act against them. No such evidence existed. There was no victim, no affidavit, and no witness present to verify that I committed a crime.
My background in legal studies includes coursework in criminal law, private investigations, criminology, forensic science, Private Investigation Methods and Techniques, constitutional law, administrative law, legal research, Criminology and Criminal Justice Fundamentals, among others.
I understand that criminal law and civil law are distinct areas of law. A traffic ticket falls under civil and administrative law, not criminal law true meaning. However, these inferior traffic court operate as a quasi criminal sector. Therefore, I did not violate any criminal statute.
Despite this, Officer Mazza issued me two tickets and unlawfully had my vehicle towed, violating my rights:
1. Failure to stop at a stop sign
2. Unregistered vehicle (which was false because my vehicle was registered; it may have required renewal, but that is not the same as being "unregistered").
This towing was illegal. The officer and the towing company failed to follow their own rules, codes, and administrative laws. The officer violated his constitutional oath.
Police Misconduct and Towing Violations
I filed a complaint against Officer Anthony D. Mazza, Badge #86, and spoke with a sergeant regarding Mazza's misconduct. The sergeant dismissed my complaint, stating that Mazza did nothing wrong and that he had the right to stop me under probable cause. He further claimed that a traffic stop and an unregistered vehicle justified towing my car and issuing me a ticket.
However, according to Glen Ridge Borough, NJ Chapter 10-05: Impound of Vehicles, the ordinance states that towing is permitted only under specific conditions, such as when a vehicle is:
• Abandoned
• Disabled
• Illegally parked
• Involved in a motor vehicle crash
• Stolen and recovered
• Suspected or identified as being involved in a criminal act
Nowhere in Glen Ridge Borough law does it state that a vehicle may be towed simply for a traffic violation or expired registration. This means that my vehicle should never have been towed under the law.
Consumer Protection Violations by E.C.R.B. Towing & Recovery
I am not a corporate entity, as indicated by my all-caps name (“NAOMI JOHNSON”); I am a natural person. The Predatory Towing Prevention Act defines a “consumer” as a natural person and requires towing companies to follow strict guidelines when conducting non-consensual tows.
Under N.J.S.A. 56:13-15, a towing company must:
• Have a business office open to the public between 8 AM and 6 PM at least five (5) days a week, excluding holidays.
• Provide reasonable accommodations for after-hours vehicle retrieval.
Additionally, under N.J.S.A. 56:13-9, non-consensual towing occurs when a vehicle is towed without the owner's or operator’s permission.
Violations by E.C.R.B. Towing:
• The company failed to provide a fee breakdown when my vehicle was towed.
• I attempted to contact the company three times:
◦ February 26, 2025 – The business was closed at 4 PM.
◦ February 27, 2025 – The business was closed again.
◦ February 28, 2025 – I finally spoke with an employee named Bill regarding my car.
• When I went to retrieve my vehicle on Saturday, March 1, 2025, the company was closed, and no accommodations were made for me.
• Bill falsely claimed that he charged me a notice fee because the company was trying to claim my vehicle title for abandonment—even though I had already contacted them and made arrangements to retrieve my car.
According to New Jersey law, a towing company must notify the vehicle owner within three days and cannot attempt to claim a salvage title unless the vehicle remains unclaimed for 15 to 30 days. My vehicle was only in their possession for seven days, yet they tried to take ownership of my car illegally.
Violations of My Constitutional and Disability Rights
• Fourth Amendment Violation: My vehicle was unlawfully seized without probable cause, a warrant, or legal justification.
• Fourteenth Amendment Violation: I was denied due process, as my property was taken without proper legal procedure.
• Disability Rights Violations: The towing of my vehicle left me stranded and in pain, worsening my pre-existing disability. I suffered severe tremors, paralysis, and extreme difficulty walking due to the stress and physical strain caused by this incident.
• Financial Loss: I was forced to leave groceries in my car, which spoiled over seven days, resulting in significant financial loss.
Demand for Investigation and Action
I have reported this incident to Chief Sean Quinn of the Glen Ridge Police Department and Joe, the owner of E.C.R.B. Towing, via certified mail. I also hand-delivered a notice to Joe’s wife, the company’s manager. Neither the police department nor the towing company has responded to my complaints.
I demand the following:
1. A full investigation into Officer Anthony D. Mazza for misconduct and unlawfully towing my vehicle.
2. A full investigation into E.C.R.B. Towing & Recovery for violating the Predatory Towing Prevention Act and New Jersey state towing laws.
3. Reimbursement of all towing fees, storage fees, and financial losses I incurred.
4. Corrective action against Glen Ridge Police Department for failing to provide accommodations for my disability and for violating constitutional protections.
5. Changes to towing policies to prevent further abuse of power and unlawful vehicle seizures.
I am disabled and cannot afford these excessive towing fees on a fixed income.
This incident was a clear violation of my constitutional rights and an abuse of power by both the police and the towing company. I request that the Consumer Financial Protection Bureau investigate this matter immediately.
Attached:
• Photos of my spoiled groceries left in the car for seven days.
• Towing company bill receipt showing improper charges
• E.C.R.B. Towing & Recovery Impound Invoice.
• U.S Postal Service certified mail receipt to Officer Anthony D. Mazza Chief of police Sean Quinn.
• Traffic tickets citation Driving or Parking an Unregistered Motor Vehicle (Citation No. 00733) and Failure to Obey Signals, Signs, or Directions (Citation No. 000734).
• Supportive event information case laws, New Jersey violation and outline of the incident.
Sincerely,
Naomi Johnson
DECLARATION OF COMPLAINT
State of New Jersey
County of Essex
I, Naomi Johnson, mailing address provision is PO BOX 202, 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. https://glenridgepoliceanthonymaza.tiiny.site/
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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