Michael Sampson, Jacqueline M. Pierro V Bergen County Prosecutor, NJ Dept of Children and Families

Case 2:14-cv-05983-ES-JAD
Ipocument 4
I 1
Filed 11/10/14 Page 1 of 31 PageiD: 35
Michael Sampson Sr.,

160 S, River Street.
No. D-98449.
Hackensack, N.J.
0760 I.
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.,
Civil Action no.

.,
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.,
COMPLAINT
42 U.S C. 1981, 1983, 1985, 1986. 1988
Defendants,
.!, 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:
Address:
D. Plaintiff:
Address:
A. S
P. S
.,
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B. Defendant# l:
Official position:
Place of Employment:
Address:
looc~ment 4
Filed
1~/~~/14
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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 tiom the town of
Garfield N.J. to aforementioned location by three individuals. One of whom, directly caused the
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Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/10/14 Page 4 of 31 PageiD: 38
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 oveneach, 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 tlueatened.
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, reasonable 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
1
means within his/her power, on or about the 8 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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Case 2:14-cv-05983-ES-JAD Document 4 Filecl11110/14 Page 7 of 31 Pagel 0: 41
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.
JAMES McMORROW
Defendant# 2:
Bergen county prosecutor's detective
Official Position :
Place of Employment: Bergen county prosecutor's Office.
lO Main Street, Hackensack, New Jersey 07601.
Address:
!.) 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 fieedoms 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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Case 2:14-cv-05983-ES-JAD Document 4 Filed 11110/14 Page 8 of 31 PageiD: 42
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 wanant 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 8 h 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 anest 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
A. S
and child# 2
Sampson, and wife Jacqueline M. Pierro. namely child# I M
P, S
. Despite being acutely aware of the fallacies he conttibuted, knowing the
A
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 McMonow, 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 dishess, 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
BRIAN GRIEFER
Bergen County prosecutor's detective
Official Position:
Place of employment: Bergen County prosecutor's Office
E. Defendant# 4:
Page 11 of 25
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Addre.ss;
lO Main Street, Hackensack, New Jersey 0760 I.
1.) Whereas: on or about July the 81h 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 employingimproper 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, Tknow 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-A2.]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
Page U of25
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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:
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'
Page 13 of25
Case 2:14-cv"05983-ES"JAD
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Oocurnent 4
I i!
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
Page 14 of2S
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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:
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, auarrest 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
Page 15 of25
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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 fiaud, 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,
Page 16 of25
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Case 2:14-cv-05983-ES-JAD Document 4 Filed 1l/10f14 Page 17 of 31 PageiD: 51
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 sh. 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.
. Page 17 of25
I
[Document 4
I.
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.
Page 18 of25
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Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/10/14 Page 19 of 31 PagelD: 53
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.
1
4). On or about the 8 h 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.
Page 19 of25
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Case 2:14-cv-05983-ES-JAD Document 4 Filed lJJl0/14 Page 20 of 31 PageiD: 54
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 conflary 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 piepared
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 wanant, 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
Page 20 of25
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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,
Page 21 of25
I I
Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/10/14 Page 22 of 31 Page!D: 56
"children of plaintiff' and of said legal union of plaintiff Michael Sampson and wife Jacqueline
M. Pieno. 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 power, by
in part, official misconduct in office.
of
10). 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, anest 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
I '
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 anest, 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 anest lacking probable cause in
Page 23 of25
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/LTROBERT 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/SRGTS. 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
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
'
I I
Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/l0/14 Page 25 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
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 1declare under penalty of perjury that the forgoing is tme.
Plaint itT
This 26'11 Day ofJune, 2014.
Page 25 of25
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) 3367304
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 occuning 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 imp!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
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 HORNYAI(, BRIAN GRIEFER, And various
orchesoation of a conspiracy, and ove1t contributory acts in supp01t of the continuous injuries, regarding
exception of discretionary, direct and knowing conspirators deviation ofstatutory obligations, to fulfill
relevant facts occuning 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
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 incuned from the continuous injuries de1iving fiom continuing the
malfeasance in suppo1ting, fllld/or sustaining the cover ups, proper and necessary to contributory manifest
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
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
THIS 2ND DAY OF MAY, 2014.
therein N.J.S.A 59:1-1
Re~pectftilly:
Mr. M. Sampson.,
~ocu~ent 4
l 1
I .
l.
'

160, South River Street, No. D-98449. Hackensack N.J. 0760 I.
Bergen county prosecutor:
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
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
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
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
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
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,
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
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.
\ ~
I.
case 2:14-cv-05983-ES-JAD Doniment 4 Filed 11/10/14 Page 29 of 31 PageJD: 63

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
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
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
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,
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
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
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.
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
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
relevant facts occurring on the 8'' of July, 2012, and shortly thereafter, which shall be relied upon in
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
thereby failing to train, and/or refrain detective(s) from officially depriving plaintiff of his right to the
obviate the very potential for liabilities incurred from the continuous injuries deriving from continuing the
intent observable in the inextricable malice motive- displayed in the contrivance, and false light of a
fraudulent, sham child abuse investigation initiated to mentally torhne the privileged wife of plaintiff, to
effectively extnct the inculpatory statements sought to further the target implication of plaintiff, by direct
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-''
! J
'.

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, Trnton, N.J. 08625-0081.
RE: Bergen eounty prosecutor:

Purview sh01t title 59: tl ~., NOTICE IS HEREBY GIVEN; a civil action complaint has been drafted
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
orchestration of a conspiracy, and ovett contributOJy acts in support of the continuous injurie-s, regarding
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
relevant facts occurring on the 8" of July, 2012, and shortly thereafter, which shall be relied upon in
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 .
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 incuned from the cominuous irjjuries deriving from continuing the
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
illocution with respe<:t to the extortion of mother to plaintiff children, used as ransom for involuntaty
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.
-;::----:;c-;;--:-:--~=----
Respecttlrlly: Mr. M. Sampson.,
l J
'.
Attentionj
Attorney 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:

Purview short title 59: ~ ~., NOTICE IS HEREBY GIVEN; a civil action complaint has been drafted
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
orchestration of a conspiracy, and ove1t contribntOJy acts in support of the continuous injuries, regarding
exception of discretionary, direct and knowing conspirators deviation of statutory obligations, to fulfill
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
bring about a wrongful indictment contra1y to standing state regulated crimina 1practice 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
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
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
illocution with respect to the extortion of mother to plaintiff children, used as ransom for involunta1y
substantive laws. All aforesaid actions perfonned by state officials with direct and knowing malice
exception of gross negligence in arbitrary [discretionay] oft1cial misconduct in office_
Please TAKE FUHTHER NOTICE: you may respond to this notice in manner and time prescribed
THIS 2ND DAY OF MAY. 2014.
therein N.J.S.A 59:1-1.
~-----,-;;-;:----:-:---:--:--c::--~-~-
Respectl\dly: Mr. M. Sampson.,

Michael Sampson, Jacqueline M. Pierro V Bergen County Prosecutor, NJ Dept of Children and Families

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Michael Sampson, Jacqueline M. Pierro V Bergen County Prosecutor, NJ Dept of Children and Families

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Case 2:14-cv-05983-ES-JAD

Filed 11/10/14 Page 1 of 31 PageiD: 35

Michael Sampson Sr.,

Civil Action Complaint

Michael Sampson, Jacqueline M. Pierro,

Civil Action no.

Bergen County Prosecutor' office,

Filecl11!10/14 Page 2 of 31 PageiD: 36

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.

Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/10/14 Page 4 of 31 PageiD: 38

Filed 11110/14 Page 5 of 31 PageiD: 39

Case 2:14-cv-05983-ES-JAD Document 4 Filecl11110/14 Page 7 of 31 Pagel 0: 41

unjustified deprivalions prohibited of personal liberty, through improper methods calculated to

Case 2:14-cv-05983-ES-JAD Document 4 Filed 11110/14 Page 8 of 31 PageiD: 42

}.)Purposive Conce1ted Actions, tantamount criminal rraud, in the constructive willfulness to

Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/10/14 Page 9 of 31 PageiD: 43

Filed 11/10/14 Page 10 of 31 PageiD: 44

Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/10/14 Page 12 of 31 PageiD: 46

Filed 11/10/14 Page 14 of 31 PageiD: 48

2.)Defendant LETICIA VERPENT for reasons unknown, accessed sensitive Division

Filed 11/10/14 Page 15 of 31 PageiD: 49

Filed 11110/14 Page 16 of 31 PageiD: 50

6. "No" official administratively appropriate relief available sought, formal or informal,

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Filed 11/10114 Page 18 of 31 PageiD: 52

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Mr. Michael Sampsou.,

Filed 11110/14 Page 27 of 31 PageiD: 61

Mr. Michael Sampson.,

RE: Bergen county prosecutor:

Filed 11/10/14 Page 28 of 31 PageiD: 62

Mr. Michael Sampson.,

Respectfully: Mr. M. Sampson.,

case 2:14-cv-05983-ES-JAD Doniment 4 Filed 11/10/14 Page 29 of 31 PageJD: 63

Mr. Michael Sampson.,

Respectfully: Mr. M. Sampson.,

Case 2:14-cv-05983-ES-JAD Document 4 Filed 11/10/14 Page 30 of 31 PageiD: 64

Ml'. Michael Sampson.,

Borough of Lodl Pollee:

Respectfully: Mr. M. Sampson.,

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

Mr. Michael Sampson.,

RE: Bergen eounty prosecutor:

Respecttlrlly: Mr. M. Sampson.,

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

RE: Bergen county prosecutor:

Respectl\dly: Mr. M. Sampson.,

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