LAW OFFICES OF

WI L L I A M J. C 0 U R T N E Y, L. L. C.
gleE a 0
o NE\I,.. JERSE'r" BAA
rJ BAR
" NEW YllRK &\R
200 M"'IN STREET
P.O. Box 112
FLEMIl-:GTON, NEW JERSEY 08822
TEL.: (908) 782-5900
F.'>X, (90S) 782·700 I
November 14, 2012
Via Regular US Mail and E-mail todcali@rosellepark.net
Borough of Roselle Park
110 East Westfield Avenue
Roselle Park, NJ 07204
Att: Doreen Cali, Clerk
RE: NOTICE OF CLAIM
Dear Ms. Cali:
(,AR[lNER O:::J
BRIAN W DERoSA 0
OF COUNSEL
Enclosed please find two Notices of Claim to be filed on behalf of George D' Agostino and
Mary D'Agostino. Please return the tiled Notices of Claim by fax to 908-782-7001.
WJC/ab
Enclosure
cc: Mary D' Agostino
George D'Agostino
Very truly yours,
William J. Courtney
File # ______ _
Clmt: ______ _
NOTICE OF CLAIM
THIS CLAIM FORM MUST BE FILED WITHIN NINETY (90) DAYS OF ACCIDENT/OCCURRENCE OR
YOU MAY FORFEIT YOUR RIGHTS PURSUANT TO N,I.S.A. 59:1 ET SEQ
FORWARD TO: BOROUGH OF ROSELLE PARK - BOROUGH CLERK OFFICE
110 EAST WESTFIELD AVENUE
ROSELLE PARK, NJ 07204
1. CLAIMANT
D'Agostino, Mary
--------------------------------------
Last First Middle (Area Code) Phone #
217 Magie Avenue
Street Address Additional Address
Roselle Park, NJ 07204
City, State, Zip Code
D/O/B SS#
2. IF NOTICE AND CORRESPONDENCE IN CONNECTION WITH THIS CLAIM ARE TO BE
SENT TO A PERSON OTHER THAN CLAIMANT, PLEASE COMPLETE ITEM #2:
J __ _
908-782-5900
Last First Middle (Area Code) Phone #
200 Main Street, P.O. Box 112
Street Add ress Additional Address

__ __ --:-- ----Flemingi-on-, -&J08[22----- -- -
City, State, Zip Code D/O/B SS#
3. A) THE OCCURRENCE OR ACCIDENT WHICH GAVE RISE TO THIS CLAIM:
september 9, 2012 9:30 P.M
Date

B) DESCRIBE THE LOCATION OR PLACE OF THE ACCIDENT OR OCCURRENCE:
Ave:'u-=-_____ _
Municipality Exact Location
File # ______ _
Clmt: ______ _
q DESCRIBE HOW THE ACCIDENT OR OCCURRENCE HAPPENED. IF A
DIAGRAM WILL ASSIST YOUR EXPLANATION, PLEASE USE THE REVERSE
SIDE OF THIS FORM:
See Attachment A.
-------------------------------------------------------------------------------------
D) STATE THE NAME, ADDRESS OF THE MUNICIPALITY OR AGENCY THAT
YOU CLAIM CAUSED YOUR DAMAGE:
Mayor Joseph Accardi, Borough of Roselle Park, 110 E. Westfield
--------------------------------------------------------------------------------------
Avenue, Roselle Park, NJ 07204-2038
--------------------------------------------------------------------------------------
E) STATE THE NAMES OF MUNICIPALITY'S EMPLOYEES WHOM YOU CLAIM
WERE AT FAULT, INCLUDING ANY INFORMATION THAT WILL ASSIST IN
IDENTIFYING THEM:
Mayor Joseph Accardi, Councilman Moe Miranda, and possibly other agents,
representatives, and employees of the Borough of Roselle Park not known
--------------------------------------------------------------------------------------
.. .at __ th.Ls __ t i l ] ) e ~ __ .. _ ... ____ .. -------- ..... ---.------.- ..... ---.
-----------------------------------------------------------------------------------
._-----.---------- -,---, - -- ---- -- - - ,-- -- ---------- ----------,----------- --- - '-
F) STATE IN DETAIL EACH AND EVERY NEGLIGENT OR WRONGFUL ACT OF
THE MUNICIPALITY EMPLOYEES WHICH CAUSED YOUR DAMAGE:
See Attachment A.
-------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------
------------------------------------------------------------------------------------.
2
File # ______ _
Clmt: ______ _
G) STATE THE NAME AND ADDRESS OF ALL WITNESSES TO THE ACCIDENT
OR OCCURRENCE:
George D'Agostino; Mary D'Agostino; Delivery Person
H) IF VEHICLE ACCIDENT, STATE THE NAMES, ADDRESS, AGE AND
RELATIONSHIP TO INSURED OF ALL PASSENGERS IN YOUR VEHICLE:
N/A

J) STATE THE NAMES OF ALL POLICE OFFICERS AND POLICE DEPARTMENTS
WHO INVESTIGATED THE ACCIDENT:
N/A
- ------- ----- -
4. A)CLAIM FOR DAMAGES (CHECK APPROPRIATE BOX):
_li_BODILY INJURY
___ PROPERTY DAMAGE __ OTHER (EXPLAIN)
-----------------------------------------------------------------------------
--------------------------------------------------------------------------
-----------------------------------------------------------------------------
------------------------------------------------------------------------------
3
File # ______ _
Clmt: ______ _
B) 1. IF YOU CLAIM INJURY, DESCRIBE YOUR INJURIES RESULTING FROM
THIS ACCIDENT OR OCCURRENCE:
emotional distress

2. DO YOU CLAIM PERMANENT DISABILITY RESULTING FROM THIS
INJURY? __ YES ______ NO
IF YES, DESCRIBE THE INJURIES BELIEVED TO BE PERMANENT:
S __ e __ __ s
3. FOR EACH HOSPITAL, DOCTOR, OR OTHER PRACTITIONER
RENDERING TREATMENT, EXAMINATION OR DIAGNOSTIC SERVICE,
STATE:
NAME & ADDRESS OF
HOSPITAL. DOCTOR OR
OTHER FACILITY
-,-- ,---
A) . --'. -
347 Llncol
AMOUNT OF
DATES OF TREATMENT CHARGED TO DATE
-i;--Pipch€ck -
Ave E
Cranford, J 07016
B)
C)
0)
AMOUNT PAID OR
PAYABLE BY OTHER
INSURANCE
4
File if ______ _
Clmt: ______ _
4. IF YOU CLAIM LOSS OF WAGES OR INCOME AS A RESULT OF THE
INJURY, STATE:
Name of Employer
Address
Your Occupation
Date Employed at this job
Rate of Pay
Dates of Absences from Wo rk
Note: IF YOUR CLAIMED LOSS OF INCOME ARISES FROM SELF-EMPLOYMENT OR
OTHER THAN WAGE, ATTACH A CALCULATION ON THE BASIS OF YOUR
CALCULATION OF LOSS INCOME.
5. SET FORTH ANY AND ALL OTHER LOSSES OR DAMAGES CLAIMED
BYYOU:
__ '=-_9 a __ __ _
__ use __ of _____________________ _
C) IF YOU CLAIM PROPERTY DAMAGE:
1. DESCRIBE THE PROPERTY DAMAGED; IF VEHICLE, INCLUDE MAKE,
MODEL, YEAR, COLOR, VEHICLE IDENTIFICATION NUMBER, LICENSE
PLATE NUMBER, STATE AND PARTS OF VEHICLE DAMAGED:
_________ ______________________________________________ _
-
2. THE PRESENT LOCATION AND TIME THE PROPERTY CAN BE
INSPECTED:
5
File # ___ '--__ _
Clmt: ______ _
3. DATE PROPERTY WAS ACQUIRED:
4. COST OF PROPERTY:
--------------------------------------------------------------------
S. VALUE OF PROPERTY AT THE TIME OF ACCIDENT:
--------------------------------------------------------------------
6. DESCRIPTION OF DAMAGE:
7. HAS THE DAMAGE BEEN REPAIRED? ____ YES ____ NO
IF YES, BY WHOM, AND COST OF REPAIRS:
N/A
--------------------------------------------------------------
8. ATIACH EACH ESTIMATE OF REPAIR COST TO THIS FORM.
9. SET FORTH IN DETAIL THE LOSS CLAIM BY YOU FOR PROPERTY
DAMAGE:
--------------------------------------------------------------------
"-- -- , - -- '- ,- --- - -
D) SET FORTH IN DETAIL ALL OTHER ITEMS OF LOSS OR DAMAGES
. CLAIMED BY YOU AND THE METHOD BY WHICH YOU MADE THE---
CALCULATIONS: .
i __ __
5) THE AMOUNT OF THE CLAIM:
rm_;" n ___ .? 1 __
0
__
obtain exnert renorts on the losses claimed

6
File # ______ _
Clmt: ______ _
6) HAVE YOU MADE A CLAIM AGAINST ANYONE ELSE FOR ANY OF THE
LOSSES OR EXPENSES CLAIMED IN THIS NOTICE?
_____ YES __ e __ NO
IF YES, SET FORTH THE NAMES AND ADDRESSES OF ALL PERSONS AND
THE INSURANCE COMPANIES AGAINST WHO YOU HAVE MADE SUCH
CLAIMS:
------------------------------------------------------------------------
------------------------------------------------------------------------
7) ARE ANY OF THE LOSSES OR EXPENSES CLAIMED HEREIN COVERED BY ANY
8)
POLICY OF INSURANCE? ____ YES __ ~ __ NO
FOR EACH SUCH POLICY, STATE THE NAME AND ADDRESS OF THE
INSURANCE COMPANY, POLICY NUMBER AND BENEFITS PAID OR PAYABLE:
HAVE YOU RECEIVED OR AGREE TO RECEIVE ANY MONEY FROM ANYONE
FOR DAMAGES CLA-IMED HEREIN? - - ~ ~ ___ YES - ~ x ~ ~ NO
IF YES, SET FORTH THE DETAILS OF SUCH AGREEMENT:
7
File # ______ _
Clmt: ______ _
9) THE FOLLOWING ITEMS MUST BE SUBMITTED WITH THIS NOTICE:
1. COPIES OF ITEMIZED BILLS FOR EACH MEDICAL EXPENSE AND OTHER
LOSSES AND EXPENSES CLAIMED.
2. FULL COPIES OF ALL APPRAISALS AND ESTIMATES OF PROPERTY
DAMAGE CLAIMED BY YOU.
3. COPIES OF ALL WRITTEN REPORTS OF ALL EXPERT WITNESSES AND
READING PHYSICIANS.
4. A LETTER FROM YOUR EMPLOYER VERIFYING YOUR LOST WAGES. IF
SELF-EMPLOYED, A STATEMENT SHOWING CALCULATIONS OF YOUR
LOST INCOME.
I HEREBY CERTIFY THAT THE FOREGOING STATEMENTS MADE BY ME ARE TRUE.
THAT THE ATTACHED STATEMENTS, BILLS, REPORTS AND DOCUMENTS ARE THE
ONLY ONE KNOWN TO ME TO BE IN EXISTENCE AT THIS TIME. I AM AWARE THAT
IF ANY STAT EM ENT MADE HEREIN IS WILLFULLY FALSE OR FRAUDULENT, I AM
SUBJECT TO PUNISHMENT AS PROVIDED BY LAW.
D
iLED/- ... L .. 4Y..I ___ _____ ._ ... _.__ _ ____ c= 2>- .- -------
z-- ON BEHALF OF CLAIMANT
--/tJ-LL1
PRINT NAME AS SIGNED ABOVE -T {
8
ATTACHMENT A
c. Describe how the accident or occurrence happened.
Claimant Mary D' Agostino was lawfully present at 293 W. Clay Avenue on
September 9, 2012, when she was injured and damaged by the intentional and/or
negligent acts of the Borough of Roselle Park, as more fully set forth in paragraph f. On
the evening in question, a delivery was being made to claimant's property on West Clay
A venue. The police arrived and questioned the delivery person, but after determining that
there was no wrongdoing, they left the scene. Shortly thereafter, at approximately 9:30
P.M, Mayor Joseph Accardi and Councilman Moe Miranda arrived at the scene, and
began to interrogate the claimant and the delivery person regarding the delivery. Mayor
Accardi and Councilman Moe Miranda assaulted, harassed, humiliated, falsely
imprisoned, and wrongfully detained the claimant and her agent, and violated the
claimant's civil, statutory, and constitutional rights, as well as the rights of her agent.
f. State in detail each and every negligent or wrongful act of the municipality and
municipal employees which caused your damage.
On the evening in question, claimant was assaulted, harassed, humiliated,
wrongfully detained, falsely imprisoned, and had her civil, statutory, and constitutional
rights violated. Said offenses were in part due to continued retaliation for civil rights and
other claims filed against the Borough of Roselle Park by claimant's husband, George
D' Agostino. This incident also constituted independent violations of the claimant's
rights under federal and state laws and constitutions. Claimant further alleges that the
Borough of Roselle Park, through its agents, representatives, and employees, including
but not limited to Mayor Joseph Accardi and Councilman Moe Miranda, acted in a
negligent manner and/or an intentional manner and caused claimant to suffer damages,
including damages for emotional distress.
File 11 ______ _
elmt: _______ _
NOTICE OF CLAIM
THIS CLAIM FORM MUST BE FILED WITHIN NINETY (90) DAYS OF ACCIDENT jOCCURRENCE OR
YOU MAY FORFEIT YOUR RIGHTS PURSUANT TO N,I.S.A. 59:1 ET SEO
FORWARD TO: BOROUGH OF ROSELLE PARK - BOROUGH CLERK OFFICE
110 EAST WESTFIELD AVENUE
ROSELLE PARK, NJ 07204
1. CLAIMANT
D'Agostino, George
-----------------------------------------------
Last First Middle (Area Code) Phone #
217 Magie Avenue
Street Address Additional Address
Roselle Park, NJ 07204
City, State, Zip Code
D/O/B SS#
2. IF NOTICE AND CORRESPONDENCE IN CONNECTION WITH THIS CLAIM ARE TO BE
SENT TO A PERSON OTHER THAN CLAIMANT, PLEASE COMPLETE ITEM #2:
q ___ _
908-782-5900
Last First Middle (Area Code) Phone #
200 Main Street, P.O. Box 112
Street Add ress Additional Address
____
City, State, Zip Code D/O/B SS#
3. A) THE OCCURRENCE OR ACCIDENT WHICH GAVE RISE TO THIS CLAIM:
September 9, 2012 9:30 P.M
Date. Time
B) DESCRIBE THE LOCATION OR PLACE OF THE ACCIDENT OR OCCURRENCE:
Roselle Park, NJ 293 W. Clay Avenue
-------------------------
Municipality Exact Location
1
File # ______ _
Clmt: ______ _
C) DESCRIBE HOW THE ACCIDENT OR OCCURRENCE HAPPENED. IF A
DIAGRAM WILL ASSIST YOUR EXPLANATION, PLEASE USE THE REVERSE
SIDE OF THIS FORM:
See Attachment A.
D) STATE THE NAME, ADDRESS OF THE MUNICIPALITY OR AGENCY THAT
YOU CLAIM CAUSED YOUR DAMAGE:
Mayor Joseph Accardi, Borough of Roselle Park, 110 E. Westfield
--------------------------------------------------------------------------------------
Avenue, Roselle Park, NJ 07204-2038
-----------------------------------------------------------------------------------
E) STATE THE NAMES OF MUNICIPALlTY;S EMPLOYEES WHOM YOU CLAIM
WERE AT FAULT, INCLUDING ANY INFORMATION THAT WILL ASSIST IN
IDENTIFYING THEM:
Mayor Joseph Accardi, Councilman Moe Miranda, and possibly other agents,
___ , __ __ __ __ Park not
.. -''It_!:hL:;,--tJ.m.e...... _ _________ ___ - -. --- - -------
-------------------------------------------------------------------------------------
---- ---------------- _.---. - -- - - - ---- --- -- ------_._--------_._-- ------------ -- . -
F) STATE IN DETAIL EACH AND EVERY NEGLIGENT OR WRONGFUL ACT OF
THE MUNICIPALITY EMPLOYEES WHICH CAUSED YOUR DAMAGE:
See Attachment A.
------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------
-------------------------------------------------------------------------------------
2
known
File # ______ _
Clmt: ______ _
G) STATE THE NAME AND ADDRESS OF ALL WITNESSES TO THE ACCIDENT
OR OCCURRENCE:
George D'Agostino; Mary D'Agostino; Delivery Person
----------------------------------------------------------------------------
H) IF VEHICLE ACCIDENT, STATE THE NAMES, ADDRESS, AGE AND
RELATIONSHIP TO INSURED OF ALL PASSENGERS IN YOUR VEHICLE:
N/A
I) STATE THE NAMES OF ALL POLICE OFFICERS AND POLICE D.EPARTMENTS
WHO INVESTIGATED THE ACCIDENT:
N/A
•. -- ------_. -- - . - . " , ~ ~ - - : ! . ~ - " " " " " - - - - - " " " " " " ~ . - - . . " . , . , . . " , , . , . . - . , . . . . . , . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _ . - - - - - - - - - - - -
4. A)CLAIM FOR DAMAGES (CHECK APPROPRIATE BOX):
_LBODllY INJURY
__ ]ROPERTY DAMAGE __ OTHER (EXPLAIN)
---------------------------------------------------------------.,..---------
-------------------------------------------------------------------------
---------------------------------------------------------------------
3
INJURY?
~ ___ YES
____ NO
IF YES, DESCRIBE THE INJURIES BELIEVED TO BE PERMANENT:
loss of sleep, anxiety
------------------------------------------------------
3, FOR EACH HOSPITAL, DOCTOR, OR OTHER PRACTITIONER
RENDERING TREATMENT, EXAMINATION OR DIAGNOSTIC SERVICE,
STATE:
NAME & ADDRESS OF
HOSPITAL, DOCTOR OR
OTHER FACILITY
BJ
q
DJ
DATES OF TREATMENT
AMOUNT OF
CHARGED TO DATE
AMOUNT PAID OR
PAYABLE BY OTHER
INSURANCE
4
File # ______ _
Clmt: ______ ___
4. IF YOU CLAIM LOSS OF WAGES OR INCOME AS A RESULT OF THE
INJURY, STATE:
Name of Employer Address
Your Occupation Date Employed at this job
Rate of Pay Dates of Absences from Work
Note: IF YOUR CLAIMED LOSS OF INCOME ARISES FROM SELF-EMPLOYMENT OR
OTHER THAN WAGE, ATTACH A CALCULATION ON THE BASIS OF YOUR
CALCULATION OF LOSS INCOME.
5. SET FORTH ANY AND ALL OTHER LOSSES OR DAMAGES CLAIMED
BY YOU:
Loss of nrospective economic gain and loss of

en"ovment and use of property.
____ _________________________________________________________ _
C) IF YOU CLAIM PROPERTY DAMAGE:
1. DESCRIBE THE PROPERTY DAMAGED; IF VEHICLE, INCLUDE MAKE,
MODEL, YEAR, COLOR, VEHICLE IDENTIFICATION NUMBER, LICENSE
PLATE NUMBER, STATE AND PARTS OF VEHICLE DAMAGED:
__ __________ _________________________________________________ _
- - '"-------...
2. THE PRESENT LOCATION AND TIME THE PROPERTY CAN BE
INSPECTED:
5
File # ___ "'-__ _
Clmt: ______ _
3. DATE PROPERTY WAS ACQUIRED:
4. COST OF PROPERTY:
--------------------------------------------------------------------
5. VALUE OF PROPERTY AT THE TIME OF ACCIDENT:
6. DESCRIPTION OF DAMAGE:
7. HAS THE DAMAGE BEEN REPAIRED? ____ YES _____ NO
IF YES, BY WHOM, AND COST OF REPAIRS:
N/A
----------------------------------------------------------------
8. ATTACH EACH ESTIMATE OF REPAIR COST TO THIS FORM.
9. SET FORTH IN DETAIL THE LOSS CLAIM BY YOU FOR PROPERTY
DAMAGE:
D) SET FORTH IN DETAIL ALL OTHER ITEMS OF LOSS OR DAMAGES
- - - CLAIMED BY YOU AND THE METHOD BY WHICH YOU MADE THE- -- -
CALCULATIONS: .
Pro s p __ __ __ proRe rt :::'_'.:
--------------------------------------------------------------------
5) THE AMOUNT OF THE CLAIM:
To be determined. Claimant reserves the right to
----------------------------------------------------------------------
obtain exnert rer.orts on the losses claimed
-----------------------------------------------
6
File IF ______ _
Clmt: ______ _
6) HAVE YOU MADE A CLAIM AGAINST ANYONE ELSE FOR ANY OF THE
LOSSES OR EXPENSES CLAIMED IN THIS NOTICE?
_____ YES __ ~ _ NO
IF YES, SET FORTH THE NAMES AND ADDRESSES OF ALL PERSONS AND
THE INSURANCE COMPANIES AGAINST WHO YOU HAVE MADE SUCH
CLAIMS:
7) ARE ANY OF THE LOSSES OR EXPENSES CLAIMED HEREIN COVERED BY ANY
8)
POLICY OF INSURANCE? ____ YES __ ~ __ NO
FOR EACH SUCH POLICY, STATE THE NAME AND ADDRESS OF THE
INSURANCE COMPANY, POLICY NUMBER AND BENEFITS PAID OR PAYABLE:
HAVE YOU RECEIVED OR AGREE TO RECEIVE ANY MONEY FROM ANYONE
FOR DAMAGES CLAIMED HEREIN? - . . . ~ ~ ~ __ YES · · _ ~ ~ ___ NO
IF YES, SET FORTH THE DETAILS OF SUCH AGREEMENT:
7
Fife # ______ _
Clmt _____ _
9) THE FOLLOWING ITEMS MUST BE SUBMITTED WITH THIS NOTICE:
1. COPIES OF ITEMIZED BILLS FOR EACH MEDICAL EXPENSE AND OTHER
LOSSES AND EXPENSES CLAIMED.
2. FULL COPIES OF ALL APPRAISALS AND ESTIMATES OF PROPERTY
DAMAGE CLAIMED BY YOU.
3. COPIES OF ALL WRITIEN REPORTS OF ALL EXPERT WITNESSES AND
READING PHYSICIANS.
4. A LETTER FROM YOUR EMPLOYER VERIFYING YOUR LOST WAGES. IF
SELF-EMPLOYED, A STATEMENT SHOWING CALCULATIONS OF YOUR
LOST INCOME.
I HEREBY CERTIFY THAT THE FOREGOING STATEMENTS MADE BY ME ARE TRUE.
THAT THE ATIACHED STATEMENTS, BILLS, REPORTS AND DOCUMENTS ARE THE
ONLY ONE KNOWN TO ME TO BE IN EXISTENCE AT THIS TIME. I AM AWARE THAT
IF ANY STATEMENT MADE HEREIN IS WILLFULLY FALSE OR FRAUDULENT, I AM
SUBJECT TO PUNISHMENT AS PROVIDED BY LAW.
-
-D-A-T!E! I .. --._--_. __
r ... _. .. .._ ClAIMANT OR PERSON fiLING ON BEHALF OF CLAIMANT
M 1IIlrm Tro"v]Acr

PRINT NAME AS SIGNED ABOVE
8
ATTACHMENT A
c. Describe how the accident or occurrence happened.
Claimant's wife, Mary D'Agostino was lawfully present at 293 W. Clay Avenue
on September 9, 2012, when she was injured and damaged by the intentional and/or
negligent acts of the Borough of Roselle Park, as more fully set forth in paragraph f. On
the evening in question, a delivery was being made to claimant's property on West Clay
Avenue. The police arrived and questioned the delivery person, but after determining that
there was no wrongdoing, they left the scene. Shortly thereafter, at approximately 9:30
P.M, Mayor Joseph Accardi and Councilman Moe Miranda arrived at the scene and
detained and interrogated claimant's wife and the delivery person regarding the delivery.
Mayor Accardi and Councilman Miranda assaulted, harassed, humiliated, falsely
imprisoned, and wrongfully detained the claimant's wife and the claimant's agent in
retaliation for litigation the claimant has filed against the Borough of Roselle Park
alleging violations of his civil, statutory, and constitutional rights, as well as the rights of
his wife and his agent.
f. State in detail each and every negligent or wrongful act of the municipality and
municipal employees which caused your damage.
The Borough of Roselle Park, through its agents, representatives, and employees,
including but not limited to Mayor Joseph Accardi and Councilman Moe Miranda,
engaged in tortuous interference with claimant's prospective economic gain, tortuous
interference with claimant's enjoyment and use of his property, negligent and/or
intentional infliction of emotional distress upon claimant, and negligence in violation of
claimant's Federal and State civil, statutory, and constitutional rights. These actions
constitute continued retaliation against the claimant for litigation he has tiled against the
Borough of Roselle Park alleging violations of his civil, statutory, and constitutional
rights. Claimant further alleges that the Borough of Roselle Park, through its agents,
representatives, and employees, including but not limited to Mayor Joseph Accardi and
Councilman Moe Miranda, acted in a negligent manner and/or an intentional manner and
caused claimant to suffer damages, including damages for emotional distress.