NJ Transit and Coach USA Death Victims Advocacy

Below is your complete, finalized Settlement Hearing Memorandum, followed by the Certificate of Service and your One-Page Cheat Sheet.

All your factual points—including the out-of-jurisdiction stop in Montclair, the written racial profiling data, the fraudulent $500 warrant, the library back-door insult, the $4,000,000 in Tort Claim Notices, the Title II ADA correction, the 3 prior Glen Ridge lawsuits, your ministerial community work, and the urgent July 18th anniversary timeline—have been meticulously integrated.

The text is formatted with clear visual anchors separating your historic foundations from binding federal laws to ensure the District Judge can scan and rule on your case strictly as a matter of law.

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

PLAINTIFF (PRO SE),
An Ordained Minister & Grieving Mother,

BOROUGH OF GLEN RIDGE, MUNICIPAL JUDGE MARK CLEMENT, PROSECUTOR ELIZABETH [LAST NAME], RISK MANAGER MICHAEL [LAST NAME], CHIEF SEAN QUINN, LT. TIMOTHY FERENNDA, SGT. DETECTIVE DANIEL MANLEY, SGT. ANTHONY MAZZA, AND E.C.R. TOWING COMPANY,
DEFENDANTS.

CASE NO: [Insert Your Federal Case Number]
HEARING DATE: July 13, 2026 (via Zoom)

PLAINTIFF’S SETTLEMENT HEARING MEMORANDUM

Plaintiff, Pro Se, respectfully submits this Settlement Hearing Memorandum to the Court in advance of the scheduled July 13, 2026, conference. Plaintiff demands that this Court strip the Defendants of qualified and sovereign immunities and enter judgment in her favor on all counts as a matter of law.

I. CHRONOLOGICAL STATEMENT OF THE UNDISPUTED MATERIAL FACTS

The Extraterritorial Seizure: On [Insert Date], Defendant Sgt. Anthony Mazza of the Glen Ridge Police Department crossed municipal boundaries into the Township of Montclair, New Jersey. Without a warrant, mutual aid agreement, or an indictable felony emergency exception, Sgt. Mazza executed a warrantless traffic stop on Plaintiff—a disabled Foundational African American woman.
The Facially Discriminatory Documentation: Sgt. Mazza issued five traffic citations. Four citations explicitly annotated Plaintiff's race as "B" (Black) or "L" (Latino) and carried an inflated fine of $55. The fifth citation contained no race code and carried a baseline fine of $45, demonstrating a facially visible pattern of racially disparate financial penalties.
The Coordinated Property Seizure: Sgt. Mazza ordered Plaintiff’s handicap-designated vehicle to be seized and towed. Private operators E.C.R. Towing Company entered Montclair and executed the tow without required authorizing municipal signatures and omitted the driver’s name from forms. Defendants left Plaintiff, a disabled citizen, stranded without a ride in violation of standard operating procedures. The car was held for seven (7) days, destroying and spoiling community grocery supplies inside.
The Fruit of the Poisonous Tree: Sgt. Mazza claims he discovered an unregistered vehicle status during the stop. However, because the underlying stop inside Montclair borders was structurally illegal, any administrative discoveries made by standing at Plaintiff's window are legally poisoned fruits of an unconstitutional entry.
Fraudulent Clerical Escalation: The initial Title 39 citations stated that a court appearance was not mandatory. Plaintiff timely filed a formal Motion to Show Cause and Notice and Motion to Vacate challenging territorial and subject-matter jurisdiction. Prosecutor Elizabeth and the Court Clerk willfully ignored the motions and unilaterally manufactured an unauthorized $500 cash bail failure-to-appear arrest warrant.
Denial of Title II ADA Accommodations: Plaintiff learned of the hidden warrant via an Internal Affairs email from Lt. Timothy Ferennda. Plaintiff immediately petitioned Municipal Judge Mark Clement for remote Zoom accommodations, providing formal medical proof of her severe disability (PTSD and neurological right-side tremors). Judge Clement explicitly refused remote access to weaponize the active warrant, callously stating in writing that Plaintiff could either pay the fines online or physically appear by "going through the back of the library" to face immediate arrest.
Borough Notice and the Monell Cover-Up: Plaintiff put the Borough on notice by serving two separate $2,000,000.00 Tort Claim Notices ($4,000,000.00 total) to Risk Manager Michael and the Court Administrator. Risk Manager Michael ignored the claims and forwarded them internally to Lt. Ferennda, who conducted a sham, rubber-stamped review to shield Sgt. Mazza. Sgt. Detective Daniel Manley explicitly refused to take a citizen report, and Chief Sean Quinn ignored formal citizen complaints.
Ongoing Severe Irreparable Harm: For over 14 continuous months, this active warrant has trapped Plaintiff in her home under fear of automated license plate scans. This unconstitutional barrier directly prevents Plaintiff from executing her religious duties as an ordained minister distributing groceries. Crucially, it inflicts severe trauma by threatening her arrest if she drives to her only son Deshon Johnson’s cemetery and memorial site on his upcoming July 18, 2026 death anniversary (five days after this hearing), and blocks her from organizing his annual university scholarship fundraisers.

II. SUMMARY OF THE ARGUMENT

This federal civil rights action does not present a triable dispute of material fact, but rather an administrative perversion of law that commands judgment for Plaintiff as a matter of law.

Plaintiff establishes her entitlement to adjudication by anchoring her claims in a seamless continuum of jurisprudence. This framework is built upon the foundational bedrock of ancient Maxims of Law, Blackstone’s Commentaries, and American Jurisprudence, which serve as the persuasive root of our legal order. This historic foundation directly supports the moving force of the Fourth, Eighth, and Fourteenth Amendments, alongside 42 U.S.C. § 1983 and Title II of the Americans with Disabilities Act (ADA).

The record confirms that Sgt. Mazza operated completely outside his territorial jurisdiction. He crossed municipal boundaries into Montclair to enforce a minor, civil Title 39 infraction. Because New Jersey law limits "fresh pursuit" strictly to indictable criminal felonies, Sgt. Mazza possessed zero police authority within Montclair. Under the Fruit of the Poisonous Tree Doctrine, his extraterritorial stop was an unconstitutional seizure; therefore, his subsequent discovery of an unregistered vehicle cannot retroactively cure the violation. The encounter and the vehicle impoundment are void ab initio—invalid from inception.

This unlawful seizure was executed through a joint civil conspiracy with E.C.R. Towing Company. Under the Federal State-Actor Doctrine, a private company that coordinates an unconstitutional property seizure with police is legally transformed into a state actor, exposing them to joint and several liability under § 1983.

The constitutional injuries were systematically compounded by the municipal court. Prosecutor Elizabeth and the Court Clerk bypassed due process by ignoring Plaintiff's jurisdictional motions. Instead, they engineered an unauthorized, punitive $500 cash bail warrant for a non-appearance ticket, directly violating the Eighth Amendment's prohibition against excessive bail.

For 14 continuous months, this invalid warrant has been weaponized by Judge Mark Clement. Judge Clement deliberately withheld remote Zoom accommodations despite receiving verified medical proof of Plaintiff’s severe disability. Forcing a disabled, grieving citizen to navigate alternative back-door library delivery entrances under threat of an invalid arrest warrant constitutes deliberate indifference under Title II of the ADA. The defense's summary judgment brief incorrectly analyzes this matter under Title I (Employment), showcasing a defective understanding of public entity mandates.

The Borough of Glen Ridge possesses actual notice of this institutional rot. They ignored Plaintiff's $4,000,000.00 in statutory Tort Claim Notices and have historically settled three major civil rights lawsuits—including a $670,000.00 settlement for internal racial discrimination and ADA failures, and a sexual assault lawsuit involving their female Police Chief. This established pattern, combined with a sham internal affairs cover-up, fully satisfies municipal liability under Monell v. Department of Social Services. Because the material facts cannot be disputed, this Court must strip the defendants of qualified immunity and enter judgment in favor of the Plaintiff as a pure matter of law.

III. LEGAL ARGUMENT & PERSUASIVE FOUNDATIONS

COUNT I: EXTRA-TERRITORIAL SEIZURE AND FRUIT OF THE POISONOUS TREE