michael sampson, jacqueline m. pierro v bergen county prosecutor, nj dept of children and families

I Case 2:14-cv-05983-ES-JAD pocument 4

Michael Sampson Sr., 160 S, River Street. No. D-98449. Hackensack, N.J. 0760 I.

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Civil Action Complaint

Michael Sampson, Jacqueline M. Pierro, Husband & wife.,

M A. S . A P. S ., infants under the age of 14 years.

By father Michael Sampson Sr. ad Litem.,

Plaintiff,

Vs.

Bergen County Prosecutor' office, Robert Anzilotti, James McMorrow, Joe Hornyak, Brian Griefer,

et a!., N.J. DCPP, Leticia Verpent,

et a!., Cliffside park boro P.D. D/Sgt S. Mackay,

et al., Lodi borough police Department, John/Jane Doe's, et al.,

Defendants,

Civil Action no.

COMPLAINT

42 U.S C. § 1981, 1983, 1985, 1986. 1988

.!, This action arises and shall rely upon: 18 U.S.C.A § 241,242,401.402.641, 1503, 1512,1623, and 1962-1964,42 U.S.C.A. § 1981, 1983.1985, 1986,1988, Amendments IV, V, VI, VIII, and XIV of The Constitution of these United States, paragraphs 1, 5, 8, and 12 of Article 1, of the constitution of this state. corollary of all relevant and salient

·acts and omissions to perform said acts constituting crimes contrary to our standing laws.

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2. Jurisdiction is asserted pursuant to: 28 U.S.C.A. § 1331, § 1343.

3. Previously dismissed Federal Civil Actions or Appeals; None.

4. Place of present confinement: Bergen county jail, Hackensack, New Jersey.

5. Parties: A. Plaintiff:

Address: Ave. New Jersey, 07026.

B. Plaintiff: Jacqueline M. Pierro., A<!dress;

C. Plaintiff: M A. S Address:

D. Plaintiff: A P. S ., Address:

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B. Defendant# l: Official position: Place of Employment:

Address:

ROBERT ANZILOTTI Bergen County prosecutor's Detective Bergen County prosecutor's Office 10 Main Street, Hackensack, New Jersey 07601.

I.) Whereas; Defendant ROBERT ANZILOTTI-on or about July the 8'h 2012. Within the jurisdiction of this court, in his individual and professional capacity as a detective, lieutenant, of the Bergen county prosecutors office. did so compromise his position of trust with respect to knowing, unilateral, decision to participate in, the initiation and constmctively orchestrate a conspiracy, against the constimted freedoms liberties and privileges provided, deprivations prohibited enui1ciated within certain inviolable substantive rights of, a united states citizen, by official depravation.of the substantive due process rights, to the equal protections of the law, owed your citizen petitioner thereby conuptly, influencing the due administration of justice through willful and wanton malice exception of official misconduct in office. In furtherance of his merely personal and private interest in the exercise of nefarious officious nature of authority, whereby embarking upon a shocking!)' transparent approach to, clandestine usurpation of public . resource and office. Thus knowingly converting to his use the record of and/or a document containing false material declarations, despite knowing the same to be false contradictions of reality prepared for the improper submissionto a New Jersey state tribunal., while acutely aware of the degree of fallacy contained within the articles contrary statutory obligations, discretionary actions taken contrary his swam obligation to uphold, the very constitutional rights due your petitioner, encroached upon, under the color and pretenses of state law and authority.

2.) on or about the s'h of July 2012, In his primary function as a lieutenant, and concurrent negligence as a supervisor of, an undisclosed number of subordinates, pnrposeful!y, and with total disregard for the observable, arbitrary abuses in availment of public office benefits, did nnlawfully caused your petitioner the hann of unlawful assault, by an unjustified deployment of the Bergen county S.W.A.T. team, and subsequent unannounced machine gun assault, to illegally arrest plaintiff with out a scintilla of required probable cause, by six or more fully armed and masked men exploding through a locked front door to a residence, upon the persons ofplaintiffMichacl Sampson Sr, and child two A P. S in actions both unethical and perfonned with extreme indifference to human life and the safety of an infant of tender 4mths of age, given the prior constructive knowledge to infant presence, procured through observable unlawful interrogation and criminal coercion of plaintiff' wife, illegally accosted, arrested in the burger king drive through line located in the borough of Lodi some 9 hours prior to, looking plaintiff in the face while standing within the fortified walls of l 00 Eisenhower Drive, Paramus N.J. whereby, defendant ,:\nzilotti did so engage in the fm1her unlawful hann and practice of unceremoniously threatening to place your petitioners children in the system, criminally charge wife of plaintiff, and make sure to get a three million dollar bail along with a charge of murder on plaintiff Michael Sampson if he failed to talk. Directly following the S.W.A.T. team extraction, and placement ofplaintitf in custodial arTest in an unmarked vehicle, hand cuffed and handed over to care of one Captain: Joe Hornyak. Then Driven ti·om the town of Garfield N.J. to aforementioned location by three individuals. One of whom, directly caused the

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arbitrary and unconstitutional ongoing harm of the unlawful bail, which sat to plaintiff left hand side in rear of vehicle, Captain: Joe ·Hom yak, while engaging in the immediate verbal effotts to character denigration of plaintiff, discriminatory and incessant labeling of murderer, "! am in your life mike, its over, you are here, I am here, doesn't that tell you something, give it up, it is over, mike I've got your [f-expletive]dog, th.e not talking role don't fly no more, that's the past, now-a-days, you talk, they all do, today the only thing between me and the door is what? Guess what, they give you up,, I've been in your house, I've got your family, you, you don't matter, I am a [f-expletive] detective, you, well, you're a murderer, Twill use everything I got to squeeze you, I will use your family against you, give me something they go home" all the words of the principle architect, detective 'Captain:' Joe Hom yak, of the prosecutors squad of criminals A.K.A. detective' unit, or a John Doe, If the cloak and dagger game played on your petitioner is to be followed. Thereby; exposing what natural perception to, oil evident sequences of the police insertion of events, giving rise to an acute awareness of the encroachment on inviolable rights denied your petitioner now proffers for redress upon the capable due c.onsideration of the courts. All direct and proximate consequences of witnessing the identical in nature and meaning, ebb and flow of words emanating at the behest of defendant Robert Anzilotti' whom did not accompany your petitioner and others in car ride, free and willful exercising of personal intellectual faculties, evidencing his incontrovertible contrary to law, manifest insttUmental complicity in the conspiracy to lll1lawfully cause the contiguous ham1 against your petitioners constitutional protections, and the inextricable prior knowledge necessaty to, concurrent causes evidencing he was influential in it's implementation, the clear and observable, constructive willfulness and attributable credit for it's adoption, and promulgation, of salient causes in fLrrtherance of the orchestration and illusion of a legitimate investigation. Equally exposing of the quantifiable indifference held and maintained for the family unit of your petitioner, and foremost distinguishable ill intent. And discrimination wherein; implementing weaponized, extreme psychological stressors designed to breakdown cerebral integrity, necessaty to implant the falsehoods required to bring about desired indicium of target; and subject husband, plaintiff Michael Sampson, achieved through direct and knowing, intentional infliction of emotional distress. Whereby, employing oveti acts of direct and knowing, improper methods of cruel and unusual persuasion employed to alter cognitive direction under pressures of reprehensible duress, predictably resulting in the intended breach of choice, caused by totality of undue abuses of police unconscionable threats undertaken to influence and bring about the hann caused your petitioner to suffer, contrary his right to constitutional freedom and liberty to common pursuits.

Calculated tactical Police oven·each, and of the specific malice of unconscionable threats to remove children, if at that time, illegally restricted of movement, thus very description of anested wife Jacqueline M. Pierro ofplaintiffMichael Sampson failed to provide a viable incLrlpatory statement, ["anything give me anything, but you gotta say something"] police actions, cootraty to federal and state laws. Furthermore, defendants fulfillt)Jent of threat, accomplished through common intent in, the calculated decisions to avail and, thereby conuptly influence an officer of the courts through and by the department of child protection and pennanency, In the discharge of his/her duty through false d.eclarations in an official intellectual article now a matter of States record, prepared with total and reckless disregard for the tntth, and in clear furtherance, of the' collectives aspirations to criminative benefit, and most recognizable ability. Determination in, th.e continuance and willfi.r! insltumental support contributed with

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respect to purposive orchestration of the gross negligent and unlawful harm, overt acts performed through [transferred malice] in· and of, the direct and knowing intentional infliction of injury the emotional distress exactly projected, therefore clear in objective to impact the innocent infant children and fmther unlawful hann of a tax paying, American family unit due the constituted equal protections of laws, the substantive laws confeJTed upon all citizens of this state. Direct and knowing, intendant circumvention of proper police procedures, notably evidencing an incontrovettible, distinguishable, contributory infringement of well known and established Constitl.ltional safeguards, which stand to extinguish, at the very least prevent such felonious restraint. Fundamental, procedural beacons put in place, in effm1s to obviate the very shocking and outrages police conduct engaged in and performed by aforesaid and heretofore, constituted public officials, at the approval of same. In the unlawful kidnap and ransom of my children.

3 .) With respect to the malice exception to the gross negligence, and deliberate indifference bleeding through the arbitrary abuses of power displayed in, the unceremonious, subjective removal and totally unnecessary intem.1ption of continuous legal custody the marital product, deriving from the lawful union of plaintiff, Michael Sampson, and wife Jacqueline M. Pierro are entitled, with outrages indifference to the ensuing harm caused by psychological ramifications of which any reasonably prudent human could have justifiably predicted, would result from such egregious, knowing, and intentional infliction of emotional distress caused to, namely child # 1 M A. S age 2, and child# 2 A P. S Age 4mounths. Direct and knowing, constructive force in the actions taken devoid of a scintilla of objectively articulable and reasonable suspicion of abuse. Which the particular statute of law perverted, ordains shmtld one venture to entreat The piece of legislation at issue, standing in suppo11 ol~ a necessary and principle element, not to mention key, 'fundumental' procedt\ral requirement to statutorily support a lawful and meritorious petition calling for the removal of children. Knowing the same article to be fabricated documentary evidence, defendant personally contributed too, while . knowing it to be pre>pared for ti.Jture presentation in court of law as material evidence contrary to evidence in a matter at bar, against the intended scope of the stale statute. As a lieutenant, possessing some official command, therefore, chief executive producer of, his said police actionable activities, director continuing in the misfeasance, the operational pace and direction of the prosecutor' office distorted, illegal, perverted, false light of investigative practice and procedure executed to unlawfully rei11oveyour petitioners children as defendant so tlu·eatened.

The fabricated operational documentation classifying as official, now a matter of State' record finally produced, to unlawfully cause the harm suffered by your petitioner, unable to withstand the sctutiny of, the cursory judicial analysis Which were Departmentally/judicially determined to be a product of unfounded fiction. Atmexed hereto, and shall respectively be referred to as [exhibit A,2], and [exhibit A, I] constmcted in co-concert with others of the same and/or other departments of state, "dutifully bound to prepare truthful reports" as a matter of state statute. Officials colorable conduct Constituting, the intrinsic fraud Defendants Snbmitted to, by way of false material declarations and, other information and perjuries, then other falsifications. Voidable matters in and of a swom affidavit, ill ihe most egregious display of [malice exception] with regard to direct and knowing abuses of office through calculated discretionary misconduct in office, of public officials witl1 the primary ftmction and obligatory onus of office, to supervise

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and lead, so enjoined with authoritative privileges of rank, conscientious incriminating choice to officiate the procurement, of the damaging fabrications in due inculpatory course, providing the legal evidence of continuous injury contrary to law now proffered.

Purposive Concerted Actions, tantamount, criminal fraud, purview standing federal and state laws. In Offering an instrument rife with false illusmy, Lmfounded infonnation for filing in a New Jersey state court, com1ption of public resource through false representation, endeavored to deceptively bring about the illegal arrest of your petitioner, Michael Sampson. Through official direct and knowing conspiratorial efforts of, his person and/or others under defendants control and/or direction as 'lieutenant' in furtherance of his persona! and private interest in achieving the ultimate goal of indicium. By willful and wanton failure to perfom1 said public duties so enjoined upon him, direct and knowing, discretionary, omission of using and exercising all proper, r·easonable and effective.lawflrl means within his power. Failure to train and/or bridle underlings actions. Thereby endorsing the constitutionally prohibited wrongs perfom~ed by his immediate subordinates against your petitioners constitutional rights. Thereby standing in agreement with methods employed to illegally create obtained evidence, in eliciting through constmctive force, false inculpatmy statements, of properly extorted, privileged wife of plaintiff, therefore criminally influencing the involuntary testimony of another for later use.

4.) Defendant Robert Anzilotti repeatedly referenced the Plaintiff using racial sluts and innuendo's. Defendant Robert Anzilotti exhibited extreme bias towards the .Plaintiff due to his status as a minority. Defendant Robert Anzilotti additionally stated that his motivation for violating the Plaintiffs Constitutionally guaranteed rights was the Plaintiffs race among other. things.

5.) Where it not for; the efficacy of the criminal coercion, executed on one Jacqueline M. Pierro the wife of said plaintiff Michael Sampson, by defendant Robert Anzilotti and/or a number of complicit subordinates under his official direction and control in his official capacity as a lieutenant, tints, saw to the events leading up and to, and pass plaintiff illegal arrest, and it shaH further lends to reasoi1 the conspirators benefitted wholly and/or in part thereof, the fnrit• of their concerted eff01ts, in the furtherance of the official depravation of the cotistitutional rights to equal protections of the laws conferred upon all by virtue of our state substantive laws and due processes thereof, long promulgated through time, along with, well established social and civil rights of United States Citizens, Michael Sampson. et. al ..

"ln each of these activities, police officers must confonn to well regulated procedures of investigative practices mandated by the constitution, which coincidentally, grants policy making authority to prosecutors, John/Jane Doe, whom .• with respect to the matters at issue. willful and wanton contributory failLlre to perfmm all said public duties so enjoined upon hin1 and/or her, by omission of using and exercising all proper, reasonable and e(fective means, and all lawful means within his/her power, on or about the 81

h of July 20[2. Hon-ibly failed to train appointed detectives. Furthemwre, whom' appointment serve' to minimize the risk of wrongful and

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unjustified deprivalions prohibited of personal liberty, through improper methods calculated to ultimately produce a wrongful conviction, subsequent to the compulsory improper knowing methods calculated to produce a wrongful palpably defective criminal indictment, With respect to designated attomey approval and arbitrmy attachment of signature to underlings frivolous, unconstitutional pursuit of a warrant which on it's face, and given the close proximity of office, prosecntor appointment of oversight to, ambassador, "prosecutors detectives" and/or bridle operatives zygnomic ventures into judicial review, and ensure the restrictions of lawful boundaries prevail, Hold and prevent the breaching of the proverbial corral, encompassed within the inviolable principals in and ofconstitutionallimitations and minimize ensuing peril of certain assured elevation of impending municipal liabilities, caused by police malicious motive, which just happens to be the core principle elements to attomey general law enforcement directive of practice, and purpose the designated attomey should stand lo provide to begin with, in representing the sovereignty, byway of, administration of justice through lawful means afforded constituted officials.

6.)Wil!fiii failure to prevent the foreseeable, substantial, undue burden the pretrial confinement unquestionably, stood to yield subjected plaintiff, and crippled his dutiful obligation of service to family, imperiled plaintiff job. interrupted his source of income. and irreparably impaired his family relationships. All on a pemicious comrpt culture and observably nefadous approacl1 to civil service, nature and quality of public official representation the, tax payer dollars afford the sovereignty, general populous, plaintiff as tax paying citizen. moreover, in the e.ye of the Jaw, a presumptively innocent man, irrespective if there were probable cause to believe he committed a crin1e.''

C. Defendant# 2: Official Position : Place of Employment: Address:

JAMES McMORROW Bergen county prosecutor's detective Bergen county prosecutor's Office. lO Main Street, Hackensack, New Jersey 07601.

!.) Whereas: on or about the 81h of July 2012. Defendant JAMES McMORROW within the

jurisdiction of this court, in his individual and professional capacity as a petective of the Bergen county prosecutors office, in discretionary actions displaying constructive willfulness, did so compromise his position oftmst with respect to knowing, unilateral. decision to cormptly, int1uence the due administration of justice throtigh his willful and wanton deception of a judicial officer of our state com1, through malice exception of official misconduct in office, in furtherance of his merely personal and private interest, in bringing about a baseless, unfounded, totally lacking of indicia warrant for a1rest, against the constitutional liberties and fi·eedoms of plaintiff Michael Sampson, despite being acutely aware to contrary to law common actions of, all pertinent co-defendants, given his contiguous and involved presence throughout all concurring events and conditions, and knowing complicity in the official deprivationofthe substantive due process rights denied of plaintiff. by lrnowingly converting to his use the record

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of, and/or a swam legal document knowing the same to be fabricated evidence prepared for the contrary to N.J law, improper submission to a New Jersey state tribunal, while acting as constituted authority under tile color of statute and pretenses of state law and office:

2.)In his primary function as, a detective of, the Bergen county prosecutor' office therefore a public offtcial, one of an rmdisclosed number of subordinates Lmder the guidance and control of aforesaid defendant #1 lieutenant Robert Anzilotti, and a yet to be known, designate<! assistant prosecutor, purposefully and with total and reckless, knowing disregard for the truth, corruptly submitted and/or transmitted allegations for a document containing knowingly false material infonnation, in the discharge of his/her duty of public office, through false declarations, knowing f\!ll well he never perceived yonr petitioner posses no such stated articles or contraband, sole nor otherwise constructively, display, proffer, nor simulate any weapon at any.point in the history of his conscious life. "in each of these activities, police must confonn to the regulated investigative

·procedures mandated by the constitution which serve to minimize the risk of wrongful and unjustified deprivations of personal liberty", ptimmily constntcted in efforts undertaken to, obviate any chances of subjecting the judicial process to undue disrepute, and promotion of widespread general distiUst in the legal system. An official intellectual at1icle, knowingly subscribed to, with total and reckless disregard for the truth, knowing the same to be illegally apprehended and knowingly projected and devised evidence prepared for futwe presentation in a comt, contrary to statutory obligation of law, as material evidence in a matter at bar, knowing the same article to be a product of unfounded fiction purview results of a competent cursmy facial analysis of the document hereafter known as [Exhibit b.) constructed in co-concert with others of the same and/or other departments of state. dutifi.llly bound to prepare truthfi.ll repons as a matter of statute, by way of false mat')rial declaration, and other inforillation, perjury, and other falsifications in official matters of, and in a sworn affidavit, in the n1ost egregious display of malice exception of abuses of office through discretionary misconduct in office of a duly constituted public official. ·

}.)Purposive Conce1ted Actions, tantamount criminal rraud, in the constructive willfulness to offer known fallacies within instrument for filing, and fi.1ture sustainment in a court of law of this state of New jersey, contrary statutory obligation, corruption of public resource through false representation, endeavored to effectively cause the illegal unlawful issuance of a complaint warrant [Exhibit b.](0290 W 2012 000529) for the purposes of causing the unlawful ham1 of bringing about the illegal anest, compounding charge and tl.nther burden plaintiff through practice of prejudicial bias socioeconomic discrimination observable in the additional hann the pecuniary obligation levied upon plaintiff to ensure denial of pretrial release, by subsequent filing of a ctiminal complaint wan·ant devoid of indicia against the freedoms and persons of plaintiff one, Michael Sampson. Through less than credible means of defendants actions and conspiratorial acquisition, direct and knowing, specific. contribl!tory infringement, and malicious eff01ts of his person and/or others iri furtherance of his personal and private interest and complicity in the conspiracy, and imposition, despite intimate knowledge of modest demographic obtained while illegally in your petitioners home conceming the strategic criminal implementation of persistent and controlled police coercion, weaponized intellectual subterfuge designed to deteriorate cognitive rationalization boundaries, inherent to any humans of

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formidable intelligence. Achieving the inevitable undue influencing, and the extraction of the distinguishably, incompetent, unreliable and manifestly involuntary, false inculpatory te~timony made under extreme duress of intentional infliction of direct and knowing brutal abuses of the police induced psychological traumas to a purported witness to a crime.

4.)Wbereby; the efficacy of the instnnuental contributory effotts in and of the collusion, and orchestration contrary to federal and state rights to due processes of the substantive laws, the massiah rule, giving rise to a distinguishable criminal coercion, executed on one Jacqueline M. Pieno with outrages extreme indifference to exposure the malicious injuries would inflicted on Jacqueline M. Pietro and inexorable psychological hanns and ramifications imposed to, the wife and equally affected children of said plaintiff Michael Sampson, by matter of record defendants # l ROBERT ANZILOTTI and defendant# 2. JAMES McMORROW and/or other coconspirators in his/her said official capacity, within said criminal maliciously motivated h.arms and encroachments stemming from procedures of an alleged investigation. It further lends to reason the conspirators benefitted wholly and/or in pmt thereof, the l!uits of their concerted efforts, in furtherance of the official depravation of the long promulgated through time, well established, constitutionally confened social and civil rights to due process of lawful substantive procedures available, and afforded all relevant and proper United States Citizens, plaintiff [Michael Sampson] and wife Jacqueline children M and A

D. Defendant# 3: Official Position: Place of employment: Address:

JOE HORNYAK Bergen County prosecutor's detective Bergen County prosecutor's Office I 0 Main Street, Hackensack, New Jersey 07601.

I.)Whe.reas; on or about the night of July the 81h 2012. defendant II 3 JOE HORNYAK within

the jurisdiction of this court, in his individual and professional capacity as a detective, Captain in the Bergen county prosecutors office, did so willfully compromise his position of trust with · respect to knowing, unilateral, decision to corruptly, influence the due administration of justice through a nl!mber of actions taken in official depravation of your petitioners constitutional right to equal protection of the laws. In clear and observable wi!lfi.ll and wanton malice exception of official misconduct in office, in furtherance of his merely personal and private interest in, personally subjecting plaintiff Michael Sampson to the unconstitutional, and unlawful han11 of illegal abduction through guise of arrest. and unlawful intenogation, during and following a machine gun assault, S.W .A.T. team extracted illegal a nest of your petitioner despite the fact he constructively knew to be lacking credible probable cause, effectively contributing to the conspiracy and official deprivation of plaintiff rights to equal protections and, due processes of our substantive laws. Furthetmore, defendants perfonnance of the llnlawful hanns and colorable, threats to "place your children in system, anest wife, place dog in pound, use everything I can to squeeze you, I will use yam family, I am in yottr life, those days of not talking, keeping your mouth shut, they gone people talk now-a-day's, when the only thing between me and/or us and

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the door, guess what, they give you up, I got your kids, I got your wife, f got your [expletive]dog, oh, you believe this [-expletive-guy, I say all that other stuff, I mention his dog I get his attention, you believe this fucking guy, why do you have a dog like that, look you will talk if you don't ill see to it you get 3million bail the whole 9 yards, like I said before, you, you're a fucking murderer, I'm a detective, I see to it you hear me." Followed by knowing individual overt acts, contrary to law, employed to bring about all threats by knowingly converting to his use the record of. and/or a documents drafted by underlings to achieve his ultimate goal, knowing all of proceeding actions taken to be contrary to his official duty to uphold laws of this State and oath with respect to federal and State constimtions. Never the less, avoiding adhering to stamtory obligations, continuing with same officiousness in all endeavors knowing them to be prepared for the improper submission, and sustainment in a New Jersey state tribunal contrary to law. In order to bring about the hann of incarceration and fmther unlawfully encroach upon the civil and social rights of plaintiff and compound the ham1s suffered by your petitioner while acting under the color of statute and pretenses of state law and authority of office,

2.)1n his primary function as a "Captain" detective in the office of the Be(gen county prosecl1tor, and one of, an undisclosed number of subordinates under the guidance and control of the county prosecutor' designated attomey, along with the aforementioned defendant #I lieutenant Robert Anzilotti, defendant # 2 JAMES McMORROW, purposefully and with total and reckless disregard for the nuth and his official duty, with respect to the matters at issue, demonstrated willful and wanton contributory failure to perfonn all said public duties so enjoined upon him and, by omission of using and exercising all proper, reasonqble and effective means, and all lawful means within his power, chose to exercise constructive willfulness and thus concurrently exposing his overwhelming contempt for what has to be, one, a man whom he knows nothing of other than outward appearances, two, legal limitations, or three, the constitutional protections. Personally those ingredienrs in any combination are a recipe for actionable harms in or out of office, add a gun and badge to the mix and hello, racist motivation aside from rhetorical innuendo rece.ived, conspiratorial effmts in an observable furtherance of the collective's orchestration of gross [transferred malice], directed upon plaintiff wife and marital product Corruptly influenced an officer of the court in the department of child protection and permanency in the discharge of his/her duty through submission of false declarations, in an official intellectual article, therein, specifically delineated and referred to by name. in said deleterious document prepared contrary to standing state laws. with total lack of integrity and displaying reckless abandon of professionalism, knowing the same to be prepared for future presentation in court of law as material evidence in, a matter of law, with respect to the outrageous ill-conceived malicious intent in fi.nther hanning your petitioner by unlawful removal and interruption of the proper and legal constitutionally recognized, statute laws protected, continuous custody of the marital product, deriving of tile lawll.ll union of plaintiff, Michael Sampson, and wife Jacqueline M. Pierro. namely child# I M A. S and child# 2 A P, S . Despite being acutely aware of the fallacies he conttibuted, knowing the same article to be a product of unfounded ftction, Pmview declaration in article hereto known as, [exhibit a, 2], dated the lO'h of July 2012,constructed in co-concert with othet's of the same and/or other departments of state, dutifully bound to prepare trnthful reports as a matter of statute, by way of false material declarations, and other purloined official information, perjuries,

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and other falsifications in official matters of and in a swom affidavit, in the most egregious display of practicable transferred malice, directed towards innocent children of plaintiff. In a disgusting show of the brand of benevolence your petitioner is accorded more often then not, malicious exception of gross negligence, and abuses of office through discretionary misconduct in office, performed by a high ranking public officials protecting and serving the general populous, the 'good guys'.

).)Purposive, Concerted Actions, tantamount criminal fraud, offering fallacies within instrument for filing, conuption of public resource through f.1lse representations, endeavored to effectively bring about the hann of unlawful arrest of plaintiff one, Michael Sampson. Through all the aforementioned and heretofore defendants observably, willful and wanton conspiratorial efforts of his and/or her person, and/or others in furiherance of his/her personal and private interest in, wanton support of an ongoing conspiracy involving the cr:iminal coercion and contributory infringement of constitlltional rights of citizens, proper and necessary to influencing the involuntary, unreliable, false inculpatory testimony of another.

4.) Wherein; the efficacy and direct and proximate hann the criminal coercion, executed on one Jacqueline M. Pierro with outrages indifference to traumatic shock directed and. caused to endure regardless of psychological ramifications sure to materialize, following exposure to deplorable actions imposed on the wife of said plaintiff Michael Sampson, during prolonged and controlled police interrogations and constructive force of threats made by defendant #1 Robert Anzilotti, defendant# 2 James McMon·ow, and defendant# 3 JOE HORNYAK as Captain. Defendants failure to train, and/or deter other co-subordinates exploits in his official capacity, thereby encouraging underlings to achieve the goal of indicium. With respect to illegally obtaining the name, therefore illegal identification of petitioner for use in, the racketeer influenced procedures evinced in methods chosen to perpetuate the unlawfully practiced acts and/or omissions of all defendants. it further lends to reason the conspirators benefitted wholly and/or in pa1t thereof, the fruits of their concerted effmts in, the tactical implementation of weaponized intellectual subterfuge, for purposes of achieving the resulting insertion and subsequent extraction of the unreliable, involuntary testimony made under extreme duress ofbnrtal police direct and knowing, intentional infliction of emotional dish·ess, induced to psychologically traumatize a pmpmted witness to a crime. In clear and observable furtherance of the official depravation of rights due, to the substantive legal processes delineated by codified N.J. criminal practice & procedures as well as long promulg.ated through time, fundamentally established social and civil state and federal constitutional rights of a proper Citizens of this State and these United States, plaintiffMicliael Sampson, and wife Jacqueline M. PietTe, children M A. S and A P. S

E. Defendant# 4: BRIAN GRIEFER Official Position: Bergen County prosecutor's detective Place of employment: Bergen County prosecutor's Office

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Addre.ss; lO Main Street, Hackensack, New Jersey 0760 I. 1.) Whereas: on or about July the 81

h 2012. Defendant BRIAN GRIEFER within the jurisdiction of this court, in his individual and professional capacity as a detective, SERGEA:-J:T, of the Bergen county prosecutors office, did so compromise his position of trust with respect to exercising constructive willfulness to lend his wanton support to bring about the ham1s suffered where b)', knowing willful and wanton failure to perform his primary duty to lead supervise and train, consistently failed to refrain from employing·improper methods and conduct in the discharge of his duty, to prevent the banns caused to plaintiffs, through and by his unilateral, decision to conuptly, influence the due administration of justice through willful and wanton malice exception of official depravations of rights and misconduct in office, in fiutherance of his merely personal and private interest in, causing the ultimate hann his contribution and promulgation in implementing the contrary to constituted duties and lawful actions in supp01t of an ongoing conspiracy to produce a wrongful illegal arrest and knowingly palpably defective criminal ii1dictment of plaintiff Michael Sampson. Police inflicted liam1 to plaintiff and family, by knowingly converting to his use the record of, and/or a docLtment, knowing the same to be prepared fot' the improper submission to a New Jersey state tribunal, contrary to state laws while acting under the guise and color of State statute and pretenses of law.

2.) In his primary fimction as Sergeant, supervisor of, an undisclosed number of subordinates purposefully and with total and reckless disregard for the tlllth, failed to prevent, and conuptly influenced an officer of the court in the depatiment of child protection and pennanency in the discharge of his/her duty, through false declarations, in an ofJicial intellectual article, an observable individual participatory act, in furtherance of the collective orchestration of the gross negligent, and ARBITRARY removal achieved through [transferred malice,] with respect to the illogical, improper methods employed in removal and, intenuption of the proper and legal custody of the marital product deriving from the lawful union of plaintiff, Michael Sampson, and wife Jacqueline M. Piel1'o namely child# 1 M A. S and child# 2 A P. S . In support of a criminal conspiracy to extOJt and incriminate and bring about the false and illegal arrest of your petitioner, while knowing he had no prior interactions, or personal knowledge as to person of plaintiff, whom can attest to the fact with all certainty, T know Not this man. Knowing the same to be prepared for future presentation in court of law as material evidence in, a matter of law, knowing the same article to be a product of unfounded fiction against your petitioners moral fibel', purview atiicle eannarked and heretofore mentioned as,[ exhibit-A·2.]constructed in co concett with others of the same and/or other departments of state, dutifully bound to prepare tmthful reports as a matter of statute, submitted, by way of false material declarations, and other information, perjuries, and other falsifications in official matters of, and in a sworn affidavit, in the most egregious display of practicable [malice exception] of abuses of office, througll calculated discretionary police misconduct in office, of a public official.

3.') Purposive Concerted Actions, tantammmt criminal fraud, offering an instrnment rife with false illusory, unfounded infonnation for filing in a New Jersey state court, col1'uption of public resource through false representation, endeavored to effectively bring about the illegal arrest of plaintiff one, Michael Sampson. Contributory infringement, Through deleterious conspiratorial

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efforts of his person, and/or others in furtherance of his personal and private interest in the illicit, criminal influencing, for intentional production of the involnntary, therefore legally unreliable false testimony of another for purposes of inculpating your petitioner in a crime.

Whereby; the efficacy of the criminal coercion, executed on one Jacqueline M. Pierro with outrages indifference to psychological ramifications imposed to, the wife of said plaintiff Michael Sampsor1, by defendants# !.ROBERT ANZTLOTTI, #2. JAMES McMORROW,# 3. JOE HORNYAK, AND #4. BRIAN GRIEFER an<Vor other subordinates under his official control and direction, in his official capacity as sergeant, it fmther lends to reason the knowing conspirators benefitted wholly and/ot· in part thereof, the fmits of their concerted efforts in the tactical implementation and bmtal execution and weaponizatio11 of intellectual subterfuge resulting in the, insertion and subsequent predictable extraction of the manifestly false, unreliable, involuntary statement made under the extreme duress of brutal abuses of police undl!e influence of psychological trauma, upon a purported witness to a crime. In furtherance of the official depravation of the due process rights and entitlement to the constitutional substantive safegnards, long promulgated through time, and fundamentally established civil and social rights of a United States Citizen, namely plaintiffMichael Sampson. Along with equally protected American wife and children.

F. De.fendant # 5: Official position: Place of Employment: Address:

LETICIA VERPENT Family Services Specialist New Jersey Division of child Protection and Pennanency 125 State Street, Hackensack, New Jersey 0760 l.

i.) Whereas: defendant LETICIA VERPENT on or about the s'h of July 2012.in her given, individuaVofficial capacity, as Family Services Specialist within the jurisdiction of this court, willfully, knowingly participated in a conspiracy, to cause unlawful harm to your petitioner in co-concert with aforementioned defendants,# 1, ROBERT ANZILOTTI, defendant #2, JAMES MCMORROW, defendant# 3, JOE HORNYAK aud # 4, BRIAN GRIEFER, hereinafter defendant# 6, S. MACKAY acting under the color of State statute and pretenses of law and office, ventured to officially impinge upon the constitutional rights ofplaintiffMichael Sampson Sr. and or plaintiffs, M A. S A P. S and one Jacqueline M. Pierro, the clear and convincing, observable implicit understanding. observable, throughout the illconceived preparation of a intellectual article, devoid of indicia, baring the date of July the lO'h 2012. blatant disregard for her occupational duty to make a truthful report, lack of any attempt ar a prima facie showing, despite the direct and knowing deliberate nnauthorized use of official office, contributory actions, attributable to the willfl!l and want011 improper calculated methods employed in the direct and knowing, conscientious submission of a record/document, coupled with willful intent to impair the objects integrity, Malicious exception of gross, negligent influencing of an official proceeding, by com1ptly influencing an officer of the c.onrt serving a United States Judge in the discharge of his/her duties respectively deputy attomey general'

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failure to perform said public duties so enjoined upon her by using and exercising all proper, reasonable and effective means and all lawful means within her power. A knowing and direct deviation of duty and statutory obligation to act in due accordance with law in ·the discharge of her public duties, willful display of discemable predisposition to improper arbitrary attachment of her signature to, a article failing to meet prevailing practice of procedures regarding the curTently standing New Jersey state laws, whereby; effect ofsig11ing. shall stand to promote the once signed, irreversible, improper. unlawful removal petition subsequent to filing with the court, instmmental in bringing about the fruits of the conspiracy.

2.)Defendant LETICIA VERPENT for reasons unknown, accessed sensitive Division information, long ago scheduled for statutory expungement-ofrecord, in an incontrovertible, clear and convincing, opposition to presently standing State Statute. Given the nature of the official infmmation purloined, clandestine acquisition, and ultimate use in a document prepared to influence the initiation of an official proceeding. arbitrary court ordered removal of children, actions inextricable ro.the v;illful intentional contribution of a willing participant, predicated by the unique occupational access to the sensitive information converted to her use in furtherance of her merely personal and private interest, in the collective of the conspiracy to infringe upon the well established, constitutionally delineated rights, plaintiff family was officially deprived of, promulgateD through out the sovereignty of these United States and of this State of New Jersey.

3.)efforts indicative of willful and wanton participation, with regard to conspiracy and ovett acts in furtherance thereof, ii1 the construct of the official Jddnapping and interference of continuous legal custody of children, officially executed, under color and pretenses of state law, usurpation of United States Department or Agency thereof, Through clear and convincing, falsification of evidence and improper submission of a document so lacking of ob_iectively reasonable, and articulable evidence giving rise to reasonable suspicion of abuse much less probable imminent danger thereof, the matter of record subscribed to under oath or affinnation, to a court, or officer thereof, knowing the same to contain false illegally obtained evidentiary statements, self serving, in the egregious, outrages, specific maliciously motivated consttuctive intent, of and in the ulterior motives behind, the collectives manifest criminative intent, to cause the reasonably predictable undue deprivation of plaintiff Michael Sampson: et al due process rights, [inter alia] in furtherance of the conspiracy to cause the official procedural deprivation of the afforded rights to due processes of the, substantive laws. In order to extract the unfounded information used to bring about the illegal kidnap, and arrest ofplaintiffMichael SamPson, through the express [transferred malice] contained in the felonious cotlduct, constituting the criminal offense. Inasmuch as the act of ransoming the legal custody of the marital product deriving of the lawful union of plaintiff Michael Sampson and wife Jacqueline M. PiCtTo, with outrages indifference to psychological ramifications imposed to, child# 1.) M A. S and child# 2.) A P. S let alone the disgusting extreme gross negligence apparent in the verifiable fact plaintiff daughter was maliciously targeted by all involved for exposure to tmconscionable food deprivation in excl1ange for an involuntary, unreliable statement procured through illicit implementation of weaponized tactical intellectual subterfuge and abusive police extraction measures, with regard to conspiracy and overt acts in furtherance thereof, a natural and predictable submission of mind and soul of a doting nurturing, not to mention nursing mother, under extreme and brutal undue influence of direct and knowing, intentionally fonnulated by

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prosecutors office, hand picked police detectives, et al, inflicted emotional distress, to achieve compulsion of statement. Negligent, contributory actions contrary federal and N.J. state laws, in continuous oveneaching and malevolence of police threats.

G). Defendant# 6: Official position: Place of Employment: Address:

S.MACKAY Detective/Sergeant Boro of Cliffside Park 525 Palisades Ave Cliffside Pk, N.J. 070 I 0.

!.) Whereas; on or about July the 8"' 2012.Defendant S. MACKAY within the jurisdiction of this court, in his individLtal and professional capacity as a detective, SERGEANT, of the Cliffside Park police department, did so compromise his position oftmst wiih respect to a knowing, unilateral, decision contrary statutory obligations, to corruptly, influence the due administration of justice throtrgh willful and wanton malice exception of official misconduct in office, in furtherance of his merely personal and private interest, in a conspiracy launched against constitutional protections provided, and depravations prohibited by- knowingly converting to his use the record of and/or a document knowing the same to contain reckless unfounded fallacies. thereby rendering belief in it's authority unreasonable, and for the improper submission to a New Jersey state tribunal, while acutely aware of all intentions of co-conspirators given his presence in transport vehicle. therefor complete knowledge of all prior events conceming police il\egalitie~ of actions for judicial review and probable cause detetmination, while acutely aware of all preceding unconstitutional acts committed for the unlawful purpose of causing the illegal arrest of plaintiff Michael Sampson, among the equally invasive wanantless "bncket test" DNA exam, au·arrest totally lacking of indicia therefore contrary the safeguards the fourth amendment clearly protect against, while acting under the guise and color statute, false pretenses of state law.

2. )In his primary function as Sergeant, supervisor of, an undisclosed number of subordinates purposefully and with total disregard for the tmth, failed to prevent, and thereby corruptly influenced an officer of the court in the discharge of his/her duty, through false declarations, in an official intellectual article, an individual participatory official act, contributing to the fi.trtherance of the col!ective orchestration of gross [transfened malice,] executed on plaintiff family with respect to the wanton complicity in a conspiracy to bring about the illegal arrest and commitment ofplaintiffMichael Sampson Sr. through willful participation in contributory infringement of right to equal protections, and observable denial of rights to, state substantive laws achieved by proper and necessary. police overreach, in coercion of Jacqueline M. Pierro and resulting from the extraction of the false testimony made under extreme duress of bmtal police induced psychological traumatization to a purported witness to a crime. perfonned under color of authority in furtherance of, an official sanctioning of the criminal removal and interruption of continuous legal custody of the marital product deriving of the lawful union of plaintiff, Michael Sampson, and wife Jacqueline M. Pierro with outrages indifference to ·

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psychological ramifications sure to stem from the direct and knowing infliction of emotional distress at hands of police with the onus to protect and serve the community, imposed to namely child# 1 M A. S and child# 2 A P. S Threats made in order to induce mother to inculpate father in crime, by proffer of confabulation, and false involuntary statements, knowing the same to be prepared for future presentation in comi of law as material evidence in a matter of law, knowing the same article to be a product of unfounded fiction, constructed in co concert with others of the same and/or other departments of state, dutifi.tlly bound to prepare truthfi.ll reports as a matter of statute, submitted, by way of false material declarations, and other infmmation, perjuries, and other falsitlcations in official matters of, and in a sworn affidavit, in support of bringing about all threats, in the most egregious display of practicable[ malice exception] of abuses of office through calculated discretionary n1isconduct in office, perfom1ed by a public official contrary to the oath to uphold the very same constitution.

3,)Purposive Concerted Actions, tantamount criminal fi·aud, offering an instrument rife with false illusory, unfounded infonnation for filing in a New Jersey state court, contrary to N.J. law, comtption of public resource through false representation, endeavored to effectively bring about the arrest of plaintiff one, Michael Sampson. As one of three individuals yom petitioner witnessed present, and knows to be privy to threats given and received during ride to prosecutors fortress, tlterefore clearly a ins1111mental contributor Through conspiratorial effmts of his person and/or others in fi.1rtherance of his personal and private interest in the illicit, influencing of the false testimony of another.

Whereof; the efficacy of the criminal coercion, executed on one Jacqueline M. Pierro with outrages indifference to psychological ramifications imposed to the wife of said plaintiffMicliael Sampson, by defendantS. MACKAY and/or other subordinates under his official control and direction, in his official capacity as sergeant, it further lends to reason the conspirators benefitted wholly and/or in patt thereof, the fmits of their concetied efforts in the implementation of, and tactical weaponization of il\tellectual subterfuge. resulting in, the predictable undue i.nfluence in and, effectively achieving the extraction of the testimony made under extreme duress of brutal police induced psychological traumatization to a purported witness to a crime .. In furtherance of the official depravation of the due process rights to, substantive laws long promulgated through time, and fundamentally established federal and State social and civil rights of a United States Citizen, plaintiff Michael Sampson.

6. "No" official administratively appropriate relief available sought, formal or informal, regarding the express acts delineated in the "Statements of claims" on page 1116-25, naturally none ventured.

There are no administrative remedies available with respect to claims stated and purview; the provisions for the private cause of action arising out of the pertinent United states code, violations, and conspirat01ial depravation, of my constitutional rights, both federal and ~tate, long standing. New Jersey Supreme coun, codified criminal practice and procedure-s,

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constitutionally protected, due process rigl1ts, to substantive laws, with regard to conspiracy and overt acts in furtherance thereof, upon persons, both proper bom and, dutifully counted, American citizen of these united states.

7. Statement of claims

a. Claim No. 1 -Defendants engaged in a violation of section 242 of title 18 U.S.C. and 2C:30: 7, 6, 2, Conspiracy to unlawfully take plaintiff into police custody, for purposes of illegal investigation and interrogation contrary N.J. 2C:l3-2, 5, thereby encroaching upon fourth amendment, with the scope and purpose of extracting information to build a case against plaintiff, in violation of the fair procedures mandated by the federal and state constitution as well as, substantive laws of this State and the, constitutional grant of authority given the supreme court of this State by article VI section II paragraph 3, to set forth and impose codified criminal practice procedure 5:7.

b. Claim No.2- Defendants did so cause the Arrest, of plaintiff Michael Sampson and wife Jacqueline M, Pierro without probable cause in violation ofFourthffourteenth amendment, imposition of arbitrary and excessive bail triple the extreme end of state directive bail schedule, in violation of the s•h. in the official deprivation of, procedural right to equal protection of the substantive laws.

c. Claim No. 3 -Contrary to N.J. criminal code 2C:28-2, 3, 5, Defendants tampered with a witness, victim, or informant, in order to influence an oft1cial proceeding, A sixth amendment violation of plaintiff right, through violation of section 1512 of title 18 U.S.C.

d, Claim No. 4- Defendants 1, 3, 4, express violation of section 1503 title 18 U.S.C. and N.J, 2C:27-12, a violation of the fourteenth amendment with regard to conspiracy and furtherance thereof,

e. Claim No.5- all defendants' willful and wanton participation through determined, individual specific conduct in violating sectionl623 of title 18 U.S.C. false declarations before grand jury or court with regard to violation of U.S.C.A. Canst. Amend. 14. in conspiracy for arbitrary unreasonable •·emoval of children and furtherance thereof.

f. Claim No. 6- Defendants both named and unnamed entered and maintained . contributory participation of a conspiracy to violate the due process rights to substantive laws of plaintiff et.al. in violation of section 241 of title 18 U.S,C. and N.J. criminal code 2C:.30-6.

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g. Claim No.7- A gross negligent violation of section 641 title 18 U.S. C. in efforts endeavored to enter illusory unfounded information to a state record, contrary N.J. 2C:28· 3, through usurpation of de.partment of child protection and permanency an equal violation ofU.S.C.A. Constitutional Amends. 8 and 14, N.J. 2C:27-12, 2C:29-l and public officials engaged in conduct constituting a crime, described by title 2C: chapter 13-1, and 4, of New Jersey criminal code; with regard to conspiracy and overt acts in furtherance thereof.

h, Claim No.8- All above captioned defendants engaged in individual conduct of contempt to standing state laws, constituting crimes in violation of section 402 of title 18 with regard to conspiracy and overt acts in furtherance thereof.

i. Claim No.9- at all pertinent times plaintiff wife was subject to illegal arrest for prolonged controlled investigative questioning purposes, repeatedly threatened with the removal of children, one in particular whom given the age and precarious point in natural and developmental dependence of service only nursing mother can provide, inevitably surrendered cerebral integrity, as can only reasonably be expected, therefor as a direct and proximate consequence of the controlled and consistent tactical police threats and undue influence, thereby rendering [plaintiff arrest] the product of the subsequent exploitation of said illegal arrest, which stands to predicate the violation of the equal protection of the law clause of the federal and State constitution. In support of all claims, plaintiff shall rely upon proscriptive defendant conduct constituting crimes, set fourth in and, described by inviolable state code of criminal justice and, of all things I find most considerable, the federal R.I.C.O statutes, furthermore, encroachment of 510 amendment, pertinent constitutional obligations mandating procedures police officers must conform to. the boundaries of law we are all to be subject to, including defendants [idj who have sworn to uphold in individual oaths of office, up to the policy making attorney general appointees whom plaintiff holds particularly accountable, in totality of the controversy, and raw abuses of power regarding the unconscionable, .malicious, ill-conceived gross negligence of the deliberate indifference shown in willfully neglecting to perform her duties as deputy attorney general, by being a party to a circumstance of such that a man or woman of ordinary intelligence and caution, standing in deputy attorney generals shoes would have been satisfied that particular violations oflaw had been or were being committed, had she read, before prejudicially, failing to refrain from arbitrarily signing off on a petition for the outrageous criminal removal of children, clearly lacking objectively reasonable suspicion of abuse, practiced in blind complicity to a sham child abuse case contrived as part of a direct and knowing improper calculate!l method to produce essential inculpatory, involuntary false statements made under duress and undue influence of prosecutors detectives infliction of emotional distress in furtherance of her merely personal and private interest in collusion of intra office contributory efforts in covering up an ongoing conspiracy to bring about the improper indictment of plaintiff.

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1). Plaintiff Michael Sampson. hereby; do solemnly invoke and assert, a natural birth right to, in and of the equal protection of all the laws, conferred upon one and all, through provisions arising out of the articulated protections provided in social and civil rights through amendments of the federal constitution of these United States and, of this State.

2). Plaintiff Michael Sampson further asserts to, the fact of long established residency in said Bergen coumy, within the disttict jurisdiction, which each defendant participant in the said conspiracy willfully engaged in substantially significant, governmental employee' deliberate, unnecessa1y, and unreasonable outrages conduct, constituting the c1iminal acts pursuant to, and in support of the conspiracy taking place in the host district of which jurisdiction is founded.

3). The govemmental body, county ofBergen, appointed officials, in positions with primary function, of managerial "supervisory oversight" in their given departments, fai Jed to bring to a halt, the undue violation of the protections provided and deprivations prohibited by state and federal substantive laws, [inter alia] of, plaintiff Michael Sampson et al, due process rights, arising out of a unconstitutionally excessive, raw abuses of power, fraudulent child abuse investigation, flippant and arbitrary attachment of deputy attomey general signature for purposes of, the unreasonable highly unethical, criminal act of removal of children irrespective requisite statutory obligation, consisting of objectively atiiculable showing of abuse. With regard to conspiratorial actions, endeavored through prosecutor's office for criminal coercion of plaintiffs wife, at expense of plaintiff children safety, to procure involuntary statement through ovett acts and conduct described as crimesby state criminal code in furtherance thereof.

4). On or about the 81h of July 2012. Defendant Robert Anzilotti Bergen county prosecutor'

office detective lieutenant knowingly threaten to and, ultimately did so knowingly a11d intentionally, circumvent, police depattment model ndes and regulations 4.3.3, and his duty to provide a truthful repott, as an individual and/or given the particular malice, executed under color of law and office, and official contributory malfeasance, observable in the criminal constntctive willfulness to, arrange or marshal the words of, an instrument known to be prepared for future presentation in a state court contrary to federal and New Jersey State laws. ln his official position of lieutenant, and intendant allotted constructive knowledge, and primary function to oversee the critical stages of a criminal investigative procedure, lent his position and tntst, to prove instrumental in spear heading sttpport of the contrivance of a conspiracy to deprive plaintiff of his constitutional right. to equal protection of law. Through actions and omissions, and his observable deleterious collusion of constituted authmities. To speak with specificity, unlawful and concerted actions necessary with regard to actual malice, in the construct at1d initiation of the, continuous injury, achieved through the wanton failure to prevent, therefore, willful participant in, the deprivation of, plaintiff constitutionally afforded substantive due process entitlement, and a constmctive fraud, vital to a known ongoing conspiracy and furtherance thereof, actions ultimately unable to withstand the scrutiny of a cursory judicial examination by an inimitable., extremely competent jurist of the superior courts of New Jersey.

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5). Defendant Robert Anzilotti did so knowingly resolve to violate plaintiff fourth and fourteenth amendment right, thereby exposing a constructive willfulness, for the failure to prevent plaintiff constitutionally guaranteed protection from unlawful searches and seizure to be impinged upon. Stood by idle while thus concunently Caused the fully disguised, armed with automatic assault weapon, criminal assault upon a father and mrrsing age infant by affectively submitting and/or knowingly, failing to prevent the entry of intentionally false statements, in a affidavit, obtained by police coerced, involuntary compulsory self-incrimination of plaintiff wife, express malice exercised against the wife and lawful marital product, "children of plaintiff' and of said legal union of plaintiff Michael Sampson and wife Jacqueline M. Pierro. Equal contributory infringement of amendment No. Vlll, state substantive due process rights, natural and probable consequences of the necessary and proper raw arbitrary abuses of power, constituting the officious and abusive gross negligence, in the clear maladministration of authority, and direct and knowing, intentional willful and wanton official misconduct in office under the supervision of county designated attorney.

6.) On or about the 8th of July 2012, Bergen county prosecutor' office deteetive defendant# 2 James McMoiTOW did knowingly threaten to and ultimately did so intentionally, circumvent, police department model mles and regulations 4.3.3, and his duty to provide a truthful report, as an individual and/or given the particu!ar.malice, executed under color of law and office, official contributory malfeasance, in a criminal procedure, specifically, the constructive willfulness to, aiTange or marshal the words of, an instmment known to be prepared for future presentation in a state court confl·ary to federal and New Jersey state law. Submitting a complaint prepared with total and reckless disregard for the truth, swom and subscribed to, before duly confim1ed cour1 judge.ln his official position of detective, and given his allotted constructive knowledge to the gross criminally negligent police activities, and primary function to prepare a tnrthful report, in the critical st.ages of a criminal investigative procedure in due accordance with state laws, officially and/or individually authored and presented the voidable deleterious, illusory intellectual article in, a particular malice of, detem1ined, contribution as a willful participant, and constmctive wanton party thereto, observable collusion of constituted authorities. To speak with specificity, displayed constructive willfulness through co11certed actions necessary with regard to actual malice, in the constmct and initiation of the, continuous injury, achieved through the feilure to prevent and, willful pm1icipation in the deprivation of. plaintiff constitutionally afforded entitlement to, due process of substantive laws. By submitting the ill pi·epared complaint to a court judge for review and further, make the probable canse detem1ination which be knew and, reasonably should have known was so lacking in indicia of probable cause as to render official belief in its existence, unreasonable. A constructive fraud, assuring the effects of, the direct and proximate consequences of, the forgoing acts and omissions of the defendants. Actions Vital to the furtherance of the conspiracy. Ultimately essential to effectively bring about the issuance of a complaint wan·ant, number [0290 W 2012 000529] a complaint unable to withstand the scrutiny of a cursory, examination, a complaint totally lacking of indicia on its face. Referenced article shall be annexed, and labeled [exhibit b.] offtcer is essentially testifying under oath or certification to an essential material fact of witnessing a crime, thTough [observation], If one is to except, and give credence to the police prepared article, affiant police officer 'purports' to have perceived, and failed to act. protect and serve, Jet alone allowed plaintiff to commit a crime, or better said failed to immediately prevent and apprehend named

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and "observed" actor, file a re~o1t, or seek issuance of complaint till after actor was dutifully committed to county jail on 9' of July 2012. .

7). On or about the 8th of July 1012, Bergen county prosecutor' office detective "Captain" defendant# 3, Joe Hornyak did knowingly and intentionally, circumvent, police depa1tment model rules and regulations 4.3.3, and his duty to provide a truthful repmi, as an individual and/or given the particular malice, executed under color oflaw and office, official contribmory misfeasance, in a criminal constructive willfulness to, arrange or marshal the words of, an instrument known to be prepared for future presentation in a state coutt contrary to federal and New Jersey State law. In his official position of detective Captain, coupled with an allotted constructive knowledge, and primary function as principal architect in, and to contribute assistance in the critical stage of a criminal procedure, spear headed the contrivance of the deleterious collusion of constituted authorities. To speak with specificity, the direct and proximate consequences of the forgoing acts and omissions of defendants concerted actions, necessary, with regard to acnral malice, in the construct and initiation of the, continuous injury, achieved through the initial overt acts, failure to prevent and, willful accomplice to deprivation of, plaintiff constitutionally afforded substantive due process entitlement, a constructive fraud, vital to conspiracy and furtherance thereof, actions ultimately unable to withstand the scrutiny of a cursory judicial examination by an inimitable, extremely competent jurist of the strperior courts of New Jersey. [exhibit a 2]

8). On or about the 8th of July 2012, Bergen county prosecutor' office detective sergeant defendant# 4, Brian Griefer did knowingly threaten and ultimately did so intentionally, circumvent, police department model rules and regulations 4.3.3, and his duty to provide a truthftil report, as an individual and/or given the particular mal ice, executed under color of Jaw and office, official contributory malfeasance, in a criminal coiJstntctive willfulness to, arrange or marshal the words of, an instrument known to be prepared for tuture presentation in a state cou11 contrary to federal and New Jersey State law. In his official position of Sergeant, allotted constructive knowledge, and primary function to oversee the critical stages of a criminal procedure he is party to, willfully contributed to the contrivance of the deleterious collusion of constituted authorities. To speak with specificity, concerted actions necessary with regard to ac111al malice, in the constntct and initiation of the, continuous injury, achieved through the. failure to prevent and, willful participation in the deprivation of, plaintiff entitlement to constitutionally afforded due process right to substantive laws, constmctive fraud, vital to conspiracy and furtherance thereof, actions ultimately unable to withstand the scmtiny of a cursory judicial examination by an inimitable, extremely competent jurist of the superior courts ofNew Jersey.

9). Defendant# 4, sergeant Brian Griefer did so knowingly violate, and willful failure to prevent the violation of plaintiff constitutionally guaranteed protection from unlawful searches and seizure, by affectively submitting knowing, intentionally false statements, in a affidavit, obtained by police oven-each, imposing undue influence, resulting in, involuntmy compulsory self-incrimination, express malice exercised against the wife and lawful marital prodnct,

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"children of plaintiff' and of said legal union of plaintiff Michael Sampson and wife Jacqueline M. Pien·o. Equal contributory infringement of due process rights to state substantive laws, natural and probable consequences of necessary and proper unconstitutionally excessive gross negligence, maladministration of authority, and intentional willfi1l arbitrary abuses of power, by in part, official misconduct in office.

1 0). On or about the 8'h of July 2012, defendant# 5 Leticia Verpent family services specialist, participated in a conspiracy forn1ulated by members of the Bergen county prosecutor's offices. Defendant# l, :?., 3, 4, 6, et aL. Robert Anzilotti, James McMorrow. Joe Hom yak, Brian Griefer S. MACKAY respectively. In an observable willful wanton intent to impair the integrity of, said intellectual article annexed hereto; and shall further be referenced to as [exhibit A,] state' document docket No.FN-02-57-13. Filed in the court of a duly confim1ed judge, the Honorable FRANCIS A. MCGROGAN, J.S.C. Cotmty of Bergen. The referenced tangible intellectual production, prepared and used as, a true and observable article, arranged as necessary and proper instrument of regularly condtJcted, state official business yet containing specific malice exception of deputy A.G. negligence, in will fl.!! failure to perform the said public duties so enjoined upon her to act in due accordance with the law in discharge of her public duties, by exercising all proper, reasonable and effective lawful means within her power, an observable constructive intent in the weaponization of the malicious process, with regard to conspiracy and overt acts in !i.utherm1ce thereof. Purview inviolable federal and State law, actions in violation of essential rights to dtle processes of federal and state substantive Jaws, constituted officials continuous operation outside the meta of law, clear and convincing complicity in the intended cOJTUption of official durie.s by causing an executive action, specific~lly the currently adopted, unconstitutional local policy of arbitrary attachment of deputy attorney general Jill StephensFlares signature to a departmental article [exhibit a.]lacking articulable, objectively reasonable suspicion required to support removal of child, raw abuses of power in opposition to, state statutory obligations Attribt1table to contributory infringement of due process rights of plaintiff, wife and children.

11). On or about the 8tl' of July 20!2, defendantS. MACKAY officially/individually willfully participated in a Bergen county prosecutors office commissioned conspiracy to deprive plaintiff of legal substantive due process rights, through complicity and contributory ove1t actions in infringement of rights, submitting a complaint prepared for judicial review and probable cause detennination which he knew and reasonably should have known was, so lacking of indicia of probable cause as to render official belief in it's existence wrreasonable, in furtherance of merely personal and private interest in bringing to a close a police investigation to a crime. And the commission of police sanctioned criminal coercion, kidnap, interruption of legal custody of children, an·est for illegal purposes, police actions conducted under color of law and office, contrary to substantive federal and State laws.

12). at subsequent review in grand display of implicit understanding the reviewing jurist abandoned his impartialjudicial role and failed to perfom1 his neutral and detached function, by

Page 22 of25

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relying on a complaint that was so lacking of indicia of probable cause as to render official belief in its existence unreasonable. The probable cause detennination consisted of no more then the judge literally "checking the box" on the complaint warrant, that probable cause was found, and further oveneaching his duty by imposing the officious, prejudicial, arbitrary, unconstitutional bail, under (state recommendation) triple the extreme end of state directive 9-05 bail schedule, of ''$250,000.00 to $1,000,000.00" as a direct and proximate conseqt1ence of forgoing acts and omissions of judicial duty, further violating excessive bail clause of plaintiff federal and state constitutional rights. An)lexed hereto plaintiff affixes exhibit c, complaint warrant [0206 W 2012 000208].

13). As a direct and proximate consequence, resulting from aforementioned acts and omissions plaintiff suffered a total and incomprehensible unmitigated, wanton deprivation of right to equal protection of law, illegal an·est, U\lWananted and/or provoked conectional officer assault by chemical spray, inmate hot fluid substance attack resulting in bums sustained to the neck and chest area, a deprivation. of exercise of service and consortium, conjugal rights to marital bed, irreplaceable loss of, experience of growth and development of marital product, child one and two, and children's personal loss of parental services, and family conso1iium, pursuit of happiness, loss of eamings potential for fiscal years 2013-2014 and counting, as holder of federal employer identification number, and small bush1ess owner, undue insolvency, irreparable damages to home stead, with regard to mortgage standing due to indefinite detention with no · foreseeable release obtainable, by exercise of. equal accord to constitutional right of reasonable pre trial bail. among other inviolable actions against well established constitutional rights, at the hands of those duly positioned to check and maintain order, uphold and respect the power of authority granting constitution, observable recalcitrance, in discretionary refusal to operate and perfom1 within the meta of law, at current ransom, personal recently acquired knowledge through virtue of necessity alone, and given the totality of events, impropriety of conduct all equally complicit in willtl.ll contributory party to allow continuance of, the extreme gross negligence regarding abuses and availment of State offices, to advance with observable impunity, [e.g.] the exposure assigned prosecutors at pertinent junctures in this controversy, in clear and convincing, incontrovertible actions, have made the inviolable courts a party thereto.

j. Relief

1) With respect to claim N:o.l of this complaint and, stated claims against defendants, both known, Bergen county prosecutor' detectives, LT-ROBERT ANZILOTTI, D/SRGTBRIAN GRIEFER, D/ JAMES MCMORROW, D/ JOE HORNYAK, Borough of Cliffside park police depat1ment, DISRGT- S. MACKAY, and unknown, Borough of Lodi police department officers whom performed initial illegal detainment of, and prevented the freedom of movement with respect to illegal arrest of plaintiff wife Jacqueline M. Pierro setting off sequence of events leading ·up to the exploitation of said illegal arrest culminating in subsequent violation of substantive due process right to equal protections of fom1h, and fourteenth amendment, illegal an·est lacking probable cause in

Page 23 of25

I I Iii


defiance of constitutional rule making power which is not subject to overriding on the s11bjcct of practice and procedure. the grant of authority given to the supreme courts by article VI, section II, paragraph 3. effected on plaintiff Michael Sampson wherefore; plaintiff demands judgment against each of these defendants, both named and unnamed, and that he be awarded: l) Punitive Damages not Jess than $9,600,000.00 2) Compensatory Damages not Jess than $9,600,000.00 and 3) Nominal Daniages;

2) With respect to claim No.2 of this complaint and, stated claims against defendants; Bergen county prosecutor' detectives, Detective/L T ·ROBERT ANZILOTTJ, Detective!SRGT-BRJAN GR!EFER .. both of whom failed to prevent, Detective/ JAMES MCMORROW, causing the issuance of complaint wanant 0?90 W 2012 000529 herein referred to as [exhibit b.] Borough of Cliffside park police department Detective/SRGT-S. MACKAY for false anest and atTest without probable cause by causing complaint warrant 026 W 2012 000208 to issue against the fourth and fourteenth amendment right of plaintiff Michael Sampson wherefore; plaintiff demands judgment against each of these defendants named, and that he be awarded: 1) Punitive Damages not less than $9,600,000.00 2) Compensatory Damages not less than $9,600,000.00 and 3) Nominal Damages;

3) With respect to claim No. 3, 5, 6, 8, and _2, of this complaint and stated claims against Defendants both known and unknown, named and unnamed, regarding official and/or individual manifest contributory support in, bringing about the finality of the events both proper and necessaty, direct and proximate foreseeable consequences to the observable clear and convincing fact reasonable belief in any of the. purloined highly uilTeliable infonnation extracted by means of undue influence of threats, to be used against the person and freedoms ofplaintiffMichael Sampson Sr. wife Jacgueline M. Pierro marital products M A. S and daughter A P. S With Regard to ovett acts in ftntherance of all pe1iinent infractiom stated in claims wherefore: plaintiff demands judgment against each of these defendants both named, and unnamed that he be awarded: l) Punitive Damages not less than $9,600.000.00 2) Compensatory Damages not less than $9,600,000.00 and 3) Nominal Damages;

4) With respect to Claim No.7 of this complaint and stated claims against defendants LETICIA VERPENT, ROBERT ANZILOTT!, BRIAN GRJEFER, JOE HORNYAK, Et.al. both known and unknown, regarding the gross violation of the substantive due Process rights of plaintiff Michael Sampson wife Jacqueline M. Pie no and children M A. S and daughter A P. S predicated by effect of signing, Rule of court state of N.J. 1:4-8. Hereto, plaintiff proffers states document marked

Page 24 of25

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Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/l0/14 of 31 PageiD: 59

Exhibit a. with respect to the usurpation of the office of child protection and permanency For the official kidnap and ransom of children MiChael A. Sampson k and Aliana P. Sampson in exchange for unreliable involuntary statement in Furtherance of conspiracy against Plaintiff Michael Sa)llPSon Sr, and Wife JacqlJeline M. Pierro wherefore; Plaintiff demands judgment against each of these defendants both named, and unnamed that he be awarded: 1) Pllnitive Damages not less than $300,000,000.00 2) Compensatory Damages not less than $300,000,000.00 and 3) Nominal Damages;

Purview short title 59: et ~-. notice of claim was drafted , dated and summarily placed in with the U.S. Mail with adequate postage attached, addressed to pertinent personnel office department heads as of the 2"d of May year of our lord 2014.

Wherefore, plaintiff request judgment against defendants for damages, cost of suit, and such other and further relief as the court may deem proper.

§_, Plaintiff respectfully requests ajmy trial: (x) Jury Trial ( ) Non-jury Tlial

Pursuant To 28 U.S.C. § 1746 1 declare under penalty of perjury that the forgoing is tme.

Plaint itT

This 26'11 Day ofJune, 2014.

Page 25 of25

! 1 11


Mr. Michael Sampsou.,

160, South River Street, No. D-98449. Hackensack N.J. 0760 I.

l(athleen A. Donovan. I Bergen county PJz., Rm. 580 Hackcns!lck, N.J. 07601. Tel; (Z01)336-7300 Fx; (201) 336·7304

Purview short title 59: et seq., NOTICE IS HEREBY GIVEN; a civil action complaint has been drafted to be sul\lmarily filed in, the district federal cow1s of this state, naming numerous agent(s), employed through your offices. But not limited to the acts and omissions of the foregoing agents and/or employees, ROBERT ANZlLOTELJAMES McMORROW, JOE HORNYAK, BRIAN GRlEFER, And various officers thereunder your employ. The civil cause of action deriving from the implementation and orchestration of a conspiracy, and overt contributory acts in support of the continuous injuries, regarding official deprivations prohibited of protections provided by constitutional rights to equal accord to the due processes of our substantive laws, as well as willful and wanton official misconduct in office, malice exception of discretionary, direct and knowing conspirators deviation of statutory obligations, to fulfill the duties so enjoined upon constituted public officials acting under the color and pretenses of law and office, inasmuch as, a collective and individual operational conduct constituting crimes described by, both· federal and state codes.

The above named plaintiff shall file said tangible article, as direct and proximate cause of salient and relevant facts occun·ing on tl1e 8th of July, 2012, and shortly thereafter. which shall be relied upon in support of c!ain1s and demand for remedies, to said county prosecutors office initiated conspiracy, to bring about a wrongful indictment contrary to standing state regulated criminal practice and procedures, current attomey general law enforcement directives) numerous constitutional violations~ executed, at the express authorization, therefore incontrovertible approval of the assigned designated Attomey('s), failure to exercise any of all proper, reasonable and effective lawful means within said power of appointment, thereby failing to train, and/or refrain detective(s) from officially depriving plaintiff of his right to tl1e due, equal protections provided by our state substantive laws, a distinguishable process of arbitrary. exercise and promulgation of local policy making authority practiced with impunity, avaihnent of the offices of child protection and permanency, among others. at a level of municipal government, placed. to obviate the very potential for liabilities incun-ed from the cDntinuous injuries deriving from continuing the malfeasance in supporting. and! or sustaining the cover ups, proper and necessaty to contributory manifest intent observable in the inextricable malice motive displayed in the contrivance, and false light of a fraudulent, sham child abuse investigation initiated to mentally totture the privileged wife of plaintiff, to effectively extract the inctJipatory statements sought to further the target i mp!ication of plaintiff, by direct and knowing infliction of emotional distress at hands of prosecutors office police and, others complicit in illocution with respect to the extortion of mother to plaintiff children, used as ransom for involuntary statement ultimately provided. Further, Equally officially depriving plaintiff protections of our substantive laws. All aforesaid actions perfonncd by state officials with direct and knowing malice exception of gross negligence in arbitraty, [discretionary] official misconduct in oftlce.

Please, TAKE FURTHER NOTICE: you may respond to this notice in manner and time prescribed in N.J.S.A 59:1-1. THIS 2ND DAY OF MAY. 2014.

Respectfully: Mr. M. Sampson.,

' I J I·

Case 2:14-cv-05983-ES-JAD Filed 11110/14 of 31 PageiD: 61

Mr. Michael Sampson., 160, South River Street, No. D-98449. Hackensack N.J. 07601.

U.S. Attorney: Paul J. Fishman, Esq.,

RE: Bergen county prosecutor: John L. Molinelli. Esq.,

Justice center. J{l Mnln Stree-t, 2116 Fl.

llaokensack. N.J. 07601.

Purview short title 59:~~ .• NOTICE IS HEREBY GIVEN; a civil action complaint has been drafted to be summarily filed in, the district federal comts of this state, naming numerous agcnt(s), employed through yotn offices. But not limited to the acts and omissions of the foregoing agents and/or employees, ROBERT ANZILOTE, JAMES McMORROW, JOE HORNY AI(, BRIAN GRIEFER, And various officers thereunder your employ. The civil cause of action deriving from the implementation and orcheso·ation of a conspiracy, and ove1t contributory acts in supp01t of the continuous injuries, regarding official deprivations prohibited of protections provided by constitutional rights to equal accord to the due processes of our substantive laws, as well as willful and wanton official misconduct in office, malice exception of discretionary, direct and knowing conspirators deviation of·statutory obligations, to fulfill the duties so enjoined upon constituted public officials acting under the color and pretenses of law and office, inasmuch as, a collective and individual operational conduct constituting crimes described by, both federal and state codes.

The above named plaintiff shall file said tangible article, as direct and proximate cause of salient and relevant facts occun·ing on the 8" of July, 2012, and shortly thereafter, which shall be relied upon in support of claims and demand for remedies, to said county prosecutors office initiated conspiracy, to bring about a wrongftrl indictment contrmy to standing state regulated criminal practice and procedures, current attorney general law enforcement directives, numerous constitutional violations, executed, at the express authorization, therefore incontrovertible approval of the assigned desig11ated Attomey('s), failure to exercise any of all proper, reasonable and effective lawful means within said power of appointment, thereby failing to train, and/or refrain detective(s) tram officially depriving plaintiff of his right to the due, equal pl'Otections provided by our state substantive laws, a distinguishable process of arbitra1y, exercise and promulgation of local policy making authority practiced with impunity, availment of the offices of child protection and permanency, among others, at a level of municipal government, placed to obviate the vety potet1tial for liabilities incun·ed from the continuous injuries de1iving fi·om continuing the malfeasance in suppo1ting, fllld/or sustaining the cover ups, proper and necessary to contributory manifest intent observable in the inextricable malice motive displayed in the contrivance, and false light of a fraudulent, slui:Jn child abuse investigation initiated to mentally torture the privileged wife of plaintiff, to effectively extract the inculpatmy statements sought to further the target implication of plaintiff, by direct and knowing infliction of emotional distress at hands of prosecutors office police and. others complicit in illocution \Vith respect to the exto11ion of mother to plaintiff children, used as ransom for involuntmy statement ultimately provided. Further, Equally officially depriving plaintiff protections of our substantive laws. All aforesaid actions performed by state officials with direct and knowing malice exception of gross negligence in arbitrary [discretionary] official misconduct in office.

Please TAKE FURTHER NOTICE: yon may respond to this notice in manner and time prescribed therein N.J.S.A 59:1-1 THIS 2ND DAY OF MAY, 2014.

Re~pectftilly: Mr. M. Sampson.,

Case 2:14-cv-05983-ES-JAD ~ocu~ent 4

I l 1 I . l.


'

Mr. Michael Sampson.,

160, South River Street, No. D-98449. Hackensack N.J. 0760 I.

Bergen county prosecutor: John L. Molinelli. Esq., 100 Eisenhower drive. Paramus N.J. 07652.

Purview short title 59:~~., NOTICE IS HEREBY GIVEN; a civil action complaint has been drafted to be summarily filed in, the district federal courts of this state, naming numerous agent(s), employed through your offices. B1rt not limited to the acts and omissions of the foregoing agents and/or employees, ROBERT ANZILOTE, .JAMES McMORROW, JOE HORNYAK, BRIAN GRIE'FER, And various officers thereunder your employ. The civil cause of action deriving from the implementation and orchestration of a conspiracy, and overt contributory acts in support of the continuous injuries, regarding official deprivations prohibited of protections proyided by constitutional rights to equal accord to the due processes of our substantive laws, as well as willful and wanton official misconduct in office, malice exception of discretionary, direct and knowing conspirators deviation of statutory obligations, to fir Ifill the duties so enjoined upon constituted public ofticials acting under the color and pretenses of law and office, inasmrrch as, a collective and individual operational conduct constituting crimes described by, both federal and state codes.

The above named plaintiff shall file said tangible article, as direct and proximate cause of salient and . relevant facts occurring on the 8th of July,2012, and sh01tly thereafter, which shall be relied upon in suppor1 of claims and demand for remedies, to said county prosecutors office initiated conspiracy, to bring about a wrongful indictment contrary to standing state regulated criminal practice and procedures, c.urrent attomey general law enforcement directives, numerous· constitutional violations, executed, at the express authorization. therefore incontrovertible approval of the assigned designated Attorney('s), failure to exercise any of all proper, reasonable and effective lawful means within said power of appointment, thereby failing to train, and/or refr;in detective(s) from officially depriving plaintiff of his right to the due, equal protections provided by our state substantive laws, a distinguishable process of arbitrary, exercise and promulgation of local policy making authority practiced with impunity, availment of the offices of child protection and pennanency, amo11g others, at a level of mu11icipal govemment, placed to obviate the very potential for liabilities incurred from the continuous injuries deriving from continuing the malfeasance in suppor1ing, and/or sustaining the cover ups, proper and necessary to contributory manifest intent observable in the inextricable malice motive displayed in the contrivance. and false light of a fraudulent, sham child abuse investigation initiated to mentally torture the privileged wife of plaintiff, to effectively extract the inculpatory statements sought to further the target implication of plaintiff, by direct and knowing infliction of emotional distress at hands of prosecutors office police and, others complicit in illocution with respect to the extortion of mother to pia inti ff children, used as ransom for involuntary statement ultimately provided. further, Equally officially depriving plaintiff protections of our substantive laws. All aforesaid actions perfom1ed by state officials with direct and knowing malice exception of gmss negligence in arbitrary, [discretionary] official misconduct in office.

Please, TAKE FURTHER NOTICE: you may respond to this notice in manner and time prescribed in N.J.S.A 59:1-1. THIS 2ND DAY OF MAY, 2014.


I \ ~ I.

case 2:14-cv-05983-ES-JAD Doniment 4 Filed 11/10/14 of 31 PageJD: 63

Mr. Michael Sampson., i

160, South River Street, No. D-98449. Hackensack N.J. 07601.

Chief of police; Cliffside pArk poli~e department 525 Palisades Ave, Cliffside park N.J. 07010.

Purview short title 59: !j ~ .• NOTIC,E IS HEREBY GIVEN_;_ a civil action complaint has been drafted to be summarily filed in, the district federal courts of this state, naming numerous agent(s), employed through your offices. SergeantS. MACKAY But not limited to the acts and omissions of the foregoing agents and/or employees, of the office' of the Bergen county prosecutor, ROBERT ANZILOTE, JAMES McMORROW, JOE HORNYAK, BRIAN GRJEFER, And various officers thereunder your employ. The civil c<Iuse of action deriving from the implementation and orchestration of a conspiracy, and ovel't contributory acts in support of the continuous injuries, regarding official deprivations prohibited of protections provided by constitutional rights to equal accord to the due processes of our substantive laws, as well as willful and wanton official misconduct in office, malice exception of discretionary, direct and knowing conspirators deviation of statutory obligations, to fulfill the duties so enjoined upon constituted public officials acting under the color and pretenses of law and office, inasmuch as; a collective and individual operational conduct constituting crimes described by, both federal and state codes.

The above named plaintiff shall file said tangible article, as direct and proximate cause of salient and relevant facts occurring on the 8'h of July, 2012, and shortly thereafter, which shall be relied upon in support of claims and, demand for remedies, to said county prosecutors office initiated conspiracy, to bring about a wrongful indictment conmuy to standing state regulated criminal practice and procedures, current attorney general lmv enforcement directives, numerous constitutional violations, executed, at the express authorization, therefore incontrovertible approval of the assigned designated Attomey('s), failure to exercise any of all proper, reasonable and effective lawful means within said power of appointment, thereby failing to train, and/or refrain detective(s) from officially depriving plaintiffofhis right to the due, equal protections provided by our state substantive Jaws, a distinguishable process of arbitrary, exercise and promulgation of local policy making authority practiced with impunity, availment of the offices of child protection and permanency, among others, at a level of municipal government, placed to obviate the very potential for liabilities incurred from the continuous injuries deriving from continuilig the malfeasance in supporting, and/or sustaining the cover ups, proper and necessary to contributory manifest intent observable in the inextricable malice motive displayed in the contrivance, and false light of a fraudulent, sham child abuse. investigation initiated to mentally tenure the privileged wife of plaintiff, to effectively extract the inculpatmy statements sought to further the target implication of plaintiff, by direct and knowing infliction of emotional distress at hands of prosecutors office police and, others complicit in illocutlon with respect to the extortion of an involuntary statement from mother to plaintiff children, used as ransom for involuntary statement ultimately provided. Further, Equally officially depriving plaintiff protections of our substantive Jaws. All aforesaid actions performed by state officials with direct and knowing malice exception of gross negligence in arbitrary [discretionary] official misconduct in office.

Please TAKE FURTHER NOTICE: you may respond to this notice in manner and time prescribed therein; N.J.S.A 59:!-l. THIS 2ND DAY OF MAY, 2014.


1 I i I.


Ml'. Michael Sampson.,

!60, South River Street, No. D-98449. Hackensack N.J. 07601.

Chief: Borough of Lodl Pollee: 1 Memorial Drive, Lodi, N.J. 07644.

Purview shOtttitle 59: !<! ~- NOTICE IS HEREBY GIVEN; a ci vii action complaint has been drafted to be summarily filed in, the district federal cotnts of this state, naming numerous agent(s), employed through your offices. But not limited to tbe acts and omissions of the foregoing county agents and/or employees, ROBERT ANZILOTE. JAMES McMORROW, JOE HORNYAK, BRIAN GRIEFER, And various officers thereunder your employ. The civil cause of action deriving from the implementation and orchestration of a conspiracy, and overt cDntributory acts in support of the continuous injuries, regarding official deprivations prohibited of protections provided by constitutional rights to equal accord to the due processes of our substantive laws, as well as willful and wanton oft1cialmisconduct in office, malice exception of discretionary, direct and knowing conspimtors deviation of statut01y obligations, to fulfill the duties so enjoined npon constituted public oft1cials acting under the color and pretenses of law and office, inasmuch as, a collective and individual operational conduct constituting crimes described by, both federal and state codes.

The above named plaintiff shall file said tangible article, as direct and proximate cause of salient and relevant facts occurring on the 8'' of July, 2012, and shortly thereafter, which shall be relied upon in support of claims and demand for remedies, to said county prosecutors office initiated conspiracy, to bring about a wrongful indictment contrary to standing state regulated criminal practice and procedures, cunent attorney general law enforcement directives, numerous constihttional violations, executed .. at the express authorization, therefore in.controvertible approval of the assigned designated Attomey('s), failure to exercise any of all proper, reasonable and effective lawful means within said power of appointment, thereby failing to train, and/or refrain detective(s) from officially depriving plaintiff of his right to the due, equal protections provided by our state substantive laws, a distinguishable process of arbitrary, exercise and promulgation of local policy making authority practiced with impunity, availment of the offices of child protection and permanency, among others, at a level of municipal government, placed to obviate the very potential for liabilities incurred from the continuous injuries deriving from continuing the malfeasance in supporting, and/or sustaining the cover ups, proper and necessary to contributory manifest intent observable in the inextricable malice motive- displayed in the contrivance, and false light of a fraudulent, sham child abuse investigation initiated to mentally torhn·e the privileged wife of plaintiff, to effectively extnct the inculpatory statements sought to further the target implication of plaintiff, by direct and knowing infliction of emotional distress at hands of prosecutors office police and, others complicit in illocution with respec.t to the extortion of mother to plaintiff children .. used as ransom for involuntary statement ultimately provided. Further, equally officially depriving pIa intiff protections of our substantive laws. All aforesaid actions petfonned by state officials with direct and knowing malice exception of gross negligence in arbitrary [discretionary] official misconduct in office.

Please: TAKE FURTHER NOTICE: you may respond to this notice in manner and time prescribed therein; N.J.S.A 59: l-l. THrS 2ND DAY OF MAY, 2014.

::------;c-;;--:-;--:-:-::------c-'' Respectfully: Mr. M. Sampson.,

I ·! ! J '. Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/10/14 of 31 PageiD: 65

Mr. Michael Sampson., 160, South River Street, No. D-98449, iackensack N.J. 0760 I.

Aftentio11; Attorney Genend: John J, Hoffman, Esq., Hughes Justice C{llnplt'-X, 25 Market St., P.O. Box 80, Tr•nton, N.J. 08625-0081.

RE: Bergen eounty prosecutor: John L. Molinelli. Esq.,

Purview sh01t title 59: tl ~., NOTICE IS HEREBY GIVEN; a civil action complaint has been drafted to be summarily filed in, the district federal courts of this state, naming numerous agent(s), employed through your offices. But not limited to the acts and omissions ofthe foregoing agents and/or employees, ROBERT ANZ:lLOTE, JAMES McMORROW, JOE HORNYAK, BRIAN GRlEFER, And various officers thereunder your employ. The civil cause of action deriving from the implementation and orchestration of a conspiracy, and ovett contributOJy acts in support of the continuous injurie-s, regarding official deprivations prohibited of protections provided by constitutional rights to equal accord to the due processes of our substantive laws, as well as willful and wanton official misconduct in office, malice exception of discretionary, direct and knowing conspirators deviation of statutory obligations, to fulf11l the duties so erlioined upon constituted public officials acting under the cnlor and pretenses of law and office, inasmuch as, a collective and individual operational conduct constituting crimes described by, both federal and state codes.

The above named plaintiff shall file said tangible article, as direct and proximate cause of salient and relevant facts occurring on the 8" of July, 2012, and shortly thereafter, which shall be relied upon in support of claims and demand for remedies, to said county prosecutors office initiated conspiracy, to bring about a wrongf\11 indictment contrary to standing state regulated criminal practice and procedures, current attorney general law er)forcement directives, numerous constitutional violations, executed, at the . express authorization, therefore incontrovertible approval of the assigned designated Attomey('s), failure to exercise any of all proper, reasonable and effective lawful means within said power of appointment, thereby failing to train, and/or refrain detective(s) from officially depriving plaintiff of his right to the due, equal protections provided by our state substantive laws, a distinguishable process of arbitrary, exercise and promulgation of local policy making authority practiced with impunity, availrnent of the offices of child protection and permanency, among others, at a level ofmuuicipal government, placed to obviate the very potential for liabilities incun·ed from the cominuous irjjuries deriving from continuing the malfeasance in supporting, and/or sustaining the cover ups, proper and necessary to contributory manifest intent observable in the inextricable malice motive displayed in the contrivance, and false light of a fraudulent, sham child abuse investigation initiated to mentally torture the privileged wife of plaintiff, to effectively extract the inculpatory statements sought to fmther the target implication of plaintiff, by direct and knowing infliction of emotional distress at hands of prosecutors office police and, others complicit in illocution with respe<:t to the extortion of mother to plaintiff children, used as ransom for involuntaty statement ultimately provided. Further, Equally officially depriving plaintiff protections of our substantive laws. All aforesaid actions perfonned by state offlcials with direct and knowing malice exception of gross negligence in arbitral)' [discretionary] official misconduct in office.

Please TAKE FURTHER NOTICE: you may respond to this notice in manner and time prescribed therein N.J.S.A 59: l-1. THIS 2ND DAY OF MAY, 2014.

-;::----:;c-;;--:-:--~=----·· Respecttlrlly: Mr. M. Sampson.,

·l l J '. Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/10/14 Page 31 of 31 PageiD: 65

Attentionj Attor·ney GenerR.I: John J. Hoffm:m, Esq., Hughes Justice Colilplrx, 2~ Market St., P.O. Box 80, Trenton, N.J. 08625-0081.

RE: Bergen county prosecutor: John L. Molinelli. Esq.,

Purview short title 59: ~ ~., NOTICE IS HEREBY GIVEN; a civil action complaint has been drafted to be summarily filed in, the district federal courts of this state, naming numerous agent(s), employed through your offices. But not limited to the acts and omissions of the foregoing agents and/or employees, ROBERT ANZlLO'"(E. JAMES McMORROW, JOE HORNYAK, BRIAN GRIEFER, And various officers thereunder your employ. The civil cause of action deriving from the implementation and orchestration of a conspiracy, and ove1t contribntOJy acts in support of the continuous injuries, regarding official deprivations prohibited of protections provided by constitutional rights to equal accord to the due processes of our substantive laws, as well as willful and wanton official misconduct in office, malice exception of discretionary, direct and knowing conspirators deviation of statutory obligations, to fulfill the duties so enjoined upon constituted public officials acting under the color and pretenses of law and office, inasmuch as, a collective and individual operational conduct constituting crimes described by, both federal and state codes.

The above named plaintiff shall file said tangible a1ticle, as direct and proximate cause of salient and relevant facts occurring on the 8" of July, 2012, and shortly thereatier, which shall be relied upon in support of claims and demand for remedies, to said county prosecutors office initiated conspiracy, to bring about a wrongful indictment contra1y to standing state regulated crimina 1 practice and procedures, current attorney general law enforcement directives, numerous constitutional violations, executed, at the . express authorization, therefore incontroveJtible approval of the assigned designated Attomey('s), failure · to exercise any of all proper, reasonable and effective lawful means within said power of appointment, thereby failing to train, and/or refrain detective(s) from officially depriving plaintiff of his right to the due, equal protections provided by oul' state substantive laws, a distinguishable process of arbitrmy, exercise and promulgation of local policy making authority practiced with impunity, avaihnent of the offices of child protection and permanency, among others, at a level of municipal government, placed to obviate the ve1y potential for liabilities incUITed from the continuous i1]juries deriving fmm continuing the malfeasance in supporting, and/or sustaining the cover ups, proper and necessa1y to contribm01y manifest intent observable in the inextricable malice motive displayed in the contrivance, and tllise light of a fraudulent, sham child abuse investiga1ion initiated to mentally torture the privileged wife of plaintiff, to effectively extract the inculpatory statements sought to fin-rher the target implication of plaintiff, by direct and knowing infliction of emotional distress at hands of prosecutors office police and, others complicit in illocution with respect to the extortion of mother· to plaintiff children, used as ransom for involunta1y statement ultimately provided. Further, Equally officially depriving plaintiff protections of our substantive laws. All aforesaid actions perfonned by state officials with direct and knowing malice exception of gross negligence in arbitrary [discretiona•y] oft1cial misconduct in office_

Please TAKE FUHTHER NOTICE: you may respond to this notice in manner and time prescribed therein N.J.S.A 59:1-1. THIS 2ND DAY OF MAY. 2014.

~-----,-;;-;:----:-:---:--:--c::--~-~-·· Respectl\dly: Mr. M. Sampson.,

michael sampson, jacqueline m. pierro v bergen county prosecutor, nj dept of children and families

Documents

s address

bergen county jail

new jersey state tribunal

defendant robert anzilotti

official position

of25 case

father michael sampson

esjad pocument