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Case 2:14-cv-05985-MCA-LDW Document 95-1 Filed 07/06/15 Page 1 of 58 PageiD: 2616

UNITED STATES- DISTRICf COURT


DISTR!Cf OF NEW JERSEY

.....
~~

<=>

Karin Wolf, individually and as-!he parent;-next


friend, and conservatrix of minors D and G;
and on behalf of All Others Similarly Situated;
and as a private attorney generalfor UNITED
STATES OF AMERICA; UNITED STATES
DEPARTMENT OF JUSHCE; INTERNAL
REVENUE SERVICE; NATIONAL
CONFERENCE OF COMMISSIONERS ON
UNIF0RM STATE LAWS (NCCUSL),
Plaintiffs and
Real Parties in Interest,

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Case number: 14-cv-5985


Plaintiff and Real Party in
Interest designates:
FEDERAL jurisdiction by
Federal Question and
Diversity of Citizenship

-againstTHE STATE-OF NEW JERSEY; GERALD C.


ESCALA; EDWARD J. CRANE; PETER
VAN AULEN, ESQ.; DR. JUDITH BROWN
GREIF; WILLIAM R. DELORENZO;
BONNIE J. MIZDOL; PETER DOYNE;
STUART RABNER; CHRIS CHRISTIE;
BERGEN COUNTY COURT; SUPERIOR
COURT OF NEW JERSEY; OFFICE OF THE
COUNTY COUNSEL; WILLIAM E.
NUGENT; HARRY G. CARROLL; ELLEN L.
KOBLITZ; JOHN C. KENNEDY; JEROME M
ST. JOHN; VICfOR ASHRAF!; JOSEPH L.
Y ANNOTTI; ADMINISTRATIVE OFFICE
OF THE COURTS (AOC); GLENN GRANT;
BERGEN FAMILY CENTER; CONSTANCE
RITZLER; JOHN CUTTITO; ALEXANDRA
STREMLER, ESQ.; ROGER RADOL, ESQ.;
DIANA MOSKAL; KATHY KATONA, ESQ.;
LISA ESTRIN; DEPARTMENT OF HEALTH
AND HUMAN SERVICES; DEPARTMENT
OF CHILDREN AND FAMILIES; DIVISION
OF CHILD PROTECf!ON AND
PERMANENCY; TARA HORNE; SANDRA
CRUZ; PATRICK YAN; DEBBIE GOMEZ;
ERIKA FRANK; DIONOS BURGOS; IV AN
NINA; FULL CIRCLE; KRISTIN CIRELLI;

TRIBUNAL AND JURY


DEMAND
[TENTATIVE]
AMENDED C9MPLAINT
for Damages, Including
Declaratory and Injunctive
Relief Under
The RICO Act -18 USC
1%1-I968; The Civil Rights
Act of 1964- Public Law 88352 (78 Stat. 241);
Color of Law- 18 USC 241,
242, 245; 42 USC 1983 and
1985, inter alia

.......
-<
C./):.."?

Case 2:14-cv-05985,MCA-LDW Document 95-1 Filed 07/06/15 Page 2 of 58 PageiD: 2617

ADVISORY COMMITIEE ON JUDICIAL


CONDUCf (ACJC); JOHN TONELLI;
*TIORNEY GENERAL OF THE STATE OF
NEW JERSEY; GOOD-SHEPHERD
SPENCER; JANET TENORE; LUCIANA
COUNTINHO CRANE; MARLENI
COUNTINHO; PLINIO COUNTINHO;
BANK OF AMERICA MERRILL LYNCH, a
corporation; BETH LAFORGIA; EDWARD
THOMPSON;BRIAN PEPE; GLEN ROCK
MIDDLE SCHOOL; GLEN ROCK BOARD
OF EDUCATION; GLENROCK POLICE
-DEPT; BERGEN GQUNTY SHERIFF; NEW
JERSEY STATE BAR ASSOCIATION;
ASSOCIATIONOFFAMILY AND
CONCILIATION COURTS (AFCC); THE
ESTATE OF RICHARD GARDNER;
NATIONAL FATHERHOOD INITIATIVE;
NATIONAL PARENTS ORGANIZATION;
D0ES,
Defendants.

Karin Wolf, plaintiff, and real party in interest pursuant to FRCP Rule 17 and 18; in her
capacity as stated herein for D and G; and on behalf of All Others Similarly Situated;
complains of the defendants as follows:
I.

Plaintiffs and Real Parties in Interest (hereinafter "Plaintiffs") declare they are not
fluent in legalese and hereby invoke the De Jure Constitution of the Republic of the
United States of America, Common Law, and Equity.

2.

Plaintiff-Karin Wolf hereby puts this Court on NOTICE that she has Post-Traumatic
Stress Disorder (PTSD) and asks this Court for accommodations pursuant to the
Americans With Disabilities Act, including extensions of time to edit, amend and revise
complaints and motions.

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3.

Plaintiff Karin hereby states that one of the problems she suffers from is hyper-prolific
writing, in literary circles known as "The Midnight Disease."

4.

1'laintiff Karin-Wolf's PTSD is a direct resultof theJ!efendants'-conduct.

5.

Part of Plaintiff's PTSD and the PTSD of All Others Similarly Situated is hypervigilance for justice caused by the defendants because they have repeatedly deprived
them of their civil rights, and most importantly their children.

6.

This causes Plaintiff Karin Wolf, her children, and All Others Similarly Situated to put
forth extensive stream-of-consciousness complaints and pleas to the courts, which while
that may annoy the Courts, is a consequential evil because these litigants are victims of
circumstance.

7.

Thus, Plaintiff's pleadings cannot be dismissed because of the disability, pursuant to


The Americans With Disabilities Act and The Civil Rights Act of 1964.

8.

Stump v. Sparkman (1978) does not apply in this case because the Americans With

Disabilities Act of 1990 trumps it.


9.

No defendants are immune in this case by virtue of the Title II of the Americans With
Disabilities Act alone.

10. No defendants are immune in this case by virtue of the Civil-Rights Act of 1964.
11. Plaintiff Karin Wolf reserves the right to amend this complaint as she has a Rule 60
Motion for Reconsideration and Motion to Quash pending before this Court at the time
of this filing, including askance for the reinstatement of parties and claims, which
would affect these pleadings and give cause for the need to amend accordingly.
12. Plaintiffs reserve the right to amend this complai.tt for any errors and/or deficiencies, as
Plaintiffs are unrepresented and filing in propria persona and sui juris.

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13. Plaintiffs reserve the right to amend this complaint and add or delete plaintiffs and
defendants after Discovery reveals further information and/or as Plaintiff Karin is able
to secur.eJegal representation for herself ~nd her_two-minor children.
14. Upon learning the true names and capacities of the DOE defendants, Plaintiffs will
amend this complaint as appropriate.
15, Plaintiffs reserve the right to submit supplemental pleadings and evidence in-further
support of this Complaint and new and continued causes of action as they occur.
16. At all times herein, Plaintiff sets forth the averments of the original complaint to
illustrate by way of example, the wrongs complained of herein.
17. At all times herein, Plaintiff sets forth the counts and causes of actions contained in her
original Complaint filed September 24,2014 as if more fully set forth herein.
18. At all times herein, all defendants are sued for sex-based and status-class-based
discrimination under The Americans With Disabilities Act of 1990 and The Civil Rights
Act of 1964.
19. At all times herein, all defendants are sued for violations of The Freedom of
Information Act, The Open Public Records Act, The Family Educational Rights and
Privacy Act.
20. At all times herein, Plaintiffs set forth averments as if more fully set forth herein.
21. At all times herein, Plaintiff incorporates the attached Table of Authorities,
Memorandum of Law, and RICO Memorandum.
22. At all times herein, Plaintiff Karin Wolf incorporates the attached exhibits by and
concerning the children, which speak of domestic violence and child abuse, to illustrate
how the defendants have tortured and continue to torture her children at present.

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23. It should be noted that the attached Judgment of Divorce under statute 2A:34-2(c) is a
finding of domestic violence.

JURISDICTION AND VENUE


24. The jurisdiction of this Court is invoked under Title 28 USC 1331.
25. This action arises under the Fourteenth Amendment of the Constitution of the United
States, section I, and the act of May 31, 1870, chapter 114, section 16, 16 Stat. -144,
(Title 8 USC 41) as hereinafter more fully appears.
26. The matter in controversy exceeds, exclusive of interest and costs, the sum or value of
Seventy-Five Thousand Dollars ($75,000).
27. The jurisdiction onhis Court is also invoked under Title 28 USC 1343.
28. This action is authorized by the Act of April 20, 1871, Chapter 22, Section 1, 17 statute
13 (Title 8 USC 43) to be commenced- by any citizen of United States or other persons
within the jurisdiction thereof to redress the deprivation, under color of a state law,
statute, ordinance, regulation, custom or usage, or rights, privileges and immunities
secured-by the Fourteenth Amendment to the Constitution of United States, section 1,
and by the act of May 31, 1870, Chapter 114, section 16, 16 Stat. 144 (Title 8 USC 41),
providing for the equal rights of citizens and of all other persons within the jurisdiction
of the United States, as hereinafter more fully appears.
29. The jurisdiction of this Court is also invoked under Title 28 USC 2284.
30. This is an action for an interlocutory injunction and a permanent injunction restraining
the enforcement, operation and executiun of statutes of the State of New Jersey by
restraining the action of c;efendants, officers of such state, in the enforcement and
execution of such statutes.

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31. The jurisdiction of this Court is invoked by 28 USC 1332; 1341; 1343(3)&(4); and
1346, which provide for original jurisdiction pursuant, but not limited to:

18 USC 1961-1%8 to-redress racketeering, influence, and corruption

42 USC 1983 and 1985; 28 USC 1331; 18 USC 241,242,245 to redress


federal constitutional and civil rights violations and conspiracy under color of
law

Civil Rights Act of 1%4 --Public Law 88-352 (78 Stat, 241) to redress
sex/gender-based and status/class-based discrimination, civil rights violations
and conspiracy

American with Disabilities Act (ADA)

Freedom of Information Act (FOIA)

Open Public Records Act (OPRA)

Family Educational Rights and Privacy Act (FERPA).

32. Venue is proper in the District of New Jersey, the Eastern District of New York, or
Southern District of New York pursuant to 28 USC l391(b) and 18 USC 1%5 et seq.
because the events giving rise to this action-occurred within all three.
33. Declaratory relief is available pursuant to 28 USC 2201 and 2202.
34. Civil remedies and treble damages are available pursuant to 18 USC 1%4, inter alia.
35. This is a proceeding for a declaratory judgment and injunction under Title 28, United
States Code, section 2201, for the purpose of determining questions in actual
controversy between the parties to wit:
36. The question of whether New Jersey Statutes -Title 26 Health and Vital Statistics, 26:828 et seq. are unconstitutional in that they force tangible human beings into a

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contract/trust and parity with the state as an artificial entity, unbeknownst and/or
misunderstood to the general public, pursuant to the void for vagueness doctrine and the
maxims of equity; and in contravention of S.C.R. i:795. Penhallow v, Doane's

Administrators (3 U.S. 54: I L.Ed. 57: 3 Dall. 54): and give to the State of New Jersey
the power to conjure domestic relations law where none originaiJ)corutherwise exists;
and which is quasi-criminal without procedural safeguards; and poweno-usurp, abuse,
abrogate, and interfere with the rights of parents to the care, custody, and control of
their own children, as protected by the First, Fourth, Fifth, Ninth, and Fourteenth
Amendments of the Constitution of the United States of America; The Social Security
Act, Title IV-D Child Support Program, 42 United States Code 1301, Section 1101, Part
A- General Provisions, (lO)(d); and human rights treaties to which the-United States is
a party - the Universal Declaration of Human Rights and the-International Covenant on
Civil and Political Rights, inter alia.
37. The question of whether the failure of the United States of America to ratify the United
Nations Convention on the Rights of the Child is unconstitutional in that it denies the
Citizens of the United States of America and its visitors equal protection by
international law while the Citizens of the 195 other countries that have ratified it are
protected; and in that the United States, having been largely instrumental in drafting the
Convention, is acting in contravention of the trust it created with other countries by
giving the appearance that it would ratify; and by extension, in contravention with The
Hague Convention in that it abrogates that trust by demanding comity while the
safegt'ards of the Convention of the Rights of the Child are not in place.

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38. The question of whether the state statutes, Title 2A, Article 8, Uniform Child Custody
Jurisdiction and Enforcement Act, 2A:34-54- 85 et seq.; 1:40-5. Mediation in Family
Part Matters; Part V. Rules Governing Practice in the Chancery Division, Family l'art,
5:1 - 5:8 et seq.; and Title 9- Children--Juvenile And Domestic Relations Courts; 9:-1 9:25 et seq., of the Statutes of New Jersey; and -the doctrine of parens patriae, are
unconstitutional in that they give to State defendants named herein the power to usurp,
abuse, abrogate and interfere with the rights of parents to the care, custody, and control
of their own children, as protected by the First, Fourth, Fifth, Ninth, and Fourteenth
Amendments of the Constitution of the United States of America; and human rights
treaties to which the United States is a party - the Universal Declaration of Human
Rights and the International Covenant on Civil and Political Rights, inter alia-.
39. The question of whether the state statutes, Title :CA, Article 8, Uniform Child Custody
Jurisdiction and Enforcement Act, 2A:34-54- 85 et seq.; 1:40-5. Mediation in Family
Part Matters; Part V. Rules Governing Practice in the Chancery Division, Family Part,
5:1-5:8 et seq.; and Title 9- Children--Juvenile And Domestic Relations Courts, 9:19:25 et seq., of the Statutes of New Jersey, are unconstitutional in that they give to State
defendants named herein the power to usurp, abuse, abrogate and interfere with the
contractual rights, including bargained-for terms of those contracts, of parents and other
persons of domestic relations.
40. The question of whether the Uniform Child Custody Jurisdiction and Enforcement Act,

2A:34-54 - 85 et seq. and 9:2-2 of the Statutes of New Jersey are unconstitutional in
that they give to State defendants named herein the power to abuse, abrogate and
interfere with the rights of parents and their children to move freely; give to State

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defendants the power to falsely imprison parents and their children; and-give-to State
defendants the power to kidnap children, as protected by_ the Right -to Freedom of
Movement pursuant to the Privileges and Immunities Clause of the Constitution of the
United States of America, Article IV, Section 2-, Clause 1; 42 United States Code 1983;
and 42 United States Code 1985, inter alia~
41. The question of whether the customs- and practices of the defendants are
unconstitutional in that they organize and maintain a de facto, sex-based and
status/class-based discriminatory policy against women, mothers and domestic vi0lence
victims; and children as domestic violence and child abuse viGtims; in divorce, child
custody and care proceedings in the courts of the State of New Jersey.
42. The question of whether the defendants manipulated and misappropriated Title IV -A
(TANF) and Title IV -D federal funding-to fofward an agenda of discrimination against

women and pad the pension plans of judges and other public servants; and whether that
is unconstitutional in that it incentivizes the State actors and family courts to self-deal,
contrary to public interest and public safety.
43. The question of whether the defendants named herein as tax-exempt, social welfare
organizations abused their 50l(c)(3) and 50!(c)(4) tax privileges by discriminating
against women and children in violation of IRS regulations.
44. The question of whether the doctrine of parens patriae is unconstitutional in that it is
based on patriarchal, antiquated and misogynistic laws and policies wherein women and
children are considered property of males, and discriminates based thereon.
45. The question of whether the child plaintiffs, solely because of status/class as domestic
violence and child abuse victims, and the subject of child custody proceedings, were

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used as pawns by the defendants under color of juvenile and domestic relations law and
the doctrine of parens patriae.
46. The question of whether the customs and practices of the defendants operating in
divorce, child custody and care proceedings in the courts-under the Statutes of New
Jersey, are unconstitutional in .thatthey deny out-of.ostate plaintiffs (including those who
plan or prefer to live out-of-state) tbe rights and privileges of receiving fair and
impartial treatment in the courts, and access to tbe same services (such as Legal Aid),
within the State and County where their cases are venued, while such rights and
privileges are granted to litigants of the State of-New-Jersey similarly situated; -where
the basis of this refusal and grant is the State Citizenship, and that alone.
47. The question of whether the domestic
Uniform

Child

Custody

r~lations

Jurisdiction

and

laws of the State of New Jersey and the


Enforcement

Act (UCCJEA)

are

unconstitutional in that they force out-of-state litigants into a legal situation of Taxation
Without Representation.
48. The question of whether the laws of the State of New Jersey that give elected officials
the ability and discretion to appoint and tenure State Judges and other public servants
are unconstitutional in that they are void for vagueness; and in contravention of the
System of Checks and Balances as provided for in Articles I, II, and III of the
Constitution; and force constituents into a legal situation of .Taxation Without
Representation.
49. The question of whether Governor Chris Christie abused his power and discretion to
appoint and tenure State Judges and other public servants whom he could control and
direct, to create an autocracy of himself and wield despotism.

10

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50. The question- of whether Chief Justice Stuart Rabner and other Sill.TE employees
appointed Gerald C. Escala back to the. bench when they knew he had accepted a bribe
and if that delegation of authority was so extensive that it lead to arbitrary prosecutions.
51. The question of whether-the Uniform Child Custody Jurisdiction and Enforcement Act
(UCCJEA) is unconstitutional in- that it denies litigants the..op)lortunity and right to
remo_ve cases to F.ederal Court based on diversity jyrisdiction; and that it does not
provide safeguards, remedies or-provisions for discriminatory practices and due process
violations of state courts.
52. The question of whether any State or Fedeml- statute or policy that bars litigants from
class-action proceedings without a attorney are unconstitutional in<hat they .prohibit
unrepresented litigants from access to justice than represented litigants similarly
situated; and in that when the defendants in those actions are judges, lawyers, public
officials, public servants, and other memoors of the legal community, there is a de facto
policy of denying litigants representation out of fear of repercussions by the legal
community and the Bar Association; and because of a de facto policy of self-imposed
nobility within the legal community.
53. The question of whether the State defendants acted m absence of subject matter
jurisdiction.
54. The question of whether the State defendants acted in absence of in personam
jurisdiction.
55. The question of whether domestic relations law should be heard in the Law Division
pursuant to 1%8 statute.

11

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5.6. The question of whether tile deprivation of-rights of a parent creates an attractiVe
nuisance to "kidnapping" their children, when the other parenr has kidnapped -th.,
children by fraud upon the court.
57. The question-of whether it is constitutional that laypersons as Citizens should be
required to obey-and

~nforce-Court

Orders when Judges have violated their rights and

haven't followed ihe Law themselves; .and those violations are in contravention to the
principles upon which this country was founded as put forth in our founding father
Benjamin Franklin's quote, "Rebellion to Tyranny is Obedience to God."
58. The question of whether defendants' actions were unconstitutional in iliat they violated
Plaintiff Karin Wolfs rights to educate her children, both.academically-and religiously.
59. The question of whether the Slate defendants acted and continue to act under color of
law to deprive plaintiffs of their rights and privileges.
60. The question of whether tfie defendants conspired and continue to deprive plaintiffs of
their rights and privileges.
61. The question of whether the defendants past and present conduct constitutes a pattern of
racketeering, influeuce, corruption, embezzlement, larceny, fraud, extortion, coercion,
bribery, domestic terrorism, treason, and other indictable offenses; and whether that
conduct is likely to continue.
62. Plaintiffs bring this action on their own behalf and also on behalf of all Citizens
similarly situated and affected, pursuant to Rule 23A of the Federal Rules of Civil
Procedure, there being common questions of law and fact affecting the rights of all
Citizens of the United States and their respective States who are similarly situated in
child custody litigation and domestic relations proceedings in which separate de facto

12

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policies are maintained against w-omen, mothers, domestic violence and child-abuse
victims, than men, and who are so numerous as to make it impractical to bring them all
before the Court.
63. The family courts of New -Jersey are under th-e control and super_vision of the Statedefendants.
64. Child plaintiffs and adult mother plaintiffs are thereby being willfully and unlawfully
discriminated against by the defendants on account of their sex/gender and status/class,
in that child plaintiffs are compelled to live with abusive parents against their
protestations, the protestations of their protective mothers, and in gross disregard for
their health and safety, solely because of the-agenda of the Fatherhood Initiative to
place men rights aoeve all others, administer a gross animus against women, and
marginalize mothers; child plaintiffs and adult mother plaintiffs are being deprived of
their rights guaranteed by the Constitution-and laws of United States.
65. Plaintiffs are suffering irreparable injury and face irreparable injury in the future by
reason of the acts herein complained of. They have no-plain, adequate or complete
remedy to redress the wrongs and illegal acts herein complained of, other than this suit
for a declaration of rights and an injunction.
66. Any other remedy to which plaintiffs might be remitted would be attended by such
uncertainties and delays as to deny substantial relief; would involve a multiplicity of
suits; and would cause further irreparable injury not only to plaintiffs, but to defendants
as governmental agencies.

PARTIES
Karin Wolf

13

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67. Plaintiff Karin Wolf (hereinafter "Karin") is an individual and Real-Party in Interest as
Conservatrix and-'Prustee of the family estate-, which encompasses the estates of herself
and her biological issueD and G as beneficiaries of the trust.

68. Plaintiff Karin Wolf is the only person with lawful custody of her children D and G.

62. f'laintiff Karin Wolf is the only person duly-authorized to act on behalf of her children.
70._ .PJaintiff Karin W:olf

obj~:cts

to anyone detaining her children and administering her

estate, as defendants are so doing at present without her consent.


71.

Plaintiff Karin Wolf is a Citizen of the State of New York-.

72. At all thnes..hereinafter mentioned, Plaintiff Karin Wolf is a female and adult.
73. At all times hereinafter mentioned, Plaintiff Karin-Wolf is the mother of D and G.
74. At all times-hereafter-mentioned, Plaintiff Karin is a Hispanic and American Indian.

D
75.

Plaintiff-D (hereinafter "D") is.an individual, minor, and natural son of Plaintiff Karin.

76. D's estate and Citizenship follows that of his mother Karin in the State of New York;
and he is heir to Karin's estate and beneficiary ol'the family estate.

77. At all times hereinafter mentioned, Plaintiff 0 is a male and a minor.


78. At all times hereafter mentioned, Plaintiff Dis a Hispanic and American Indian.

79. At all times hereafter mentioned, Plaintiff D is a victim of child abuse and domestic
violence by Defendant CRANE.
G
80.

Plaintiff G (hereinafter "G") is an individual, minor, and natural daughter of Plaintiff


Karin.

14

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81. G's estate an<} Citizenship follows that of her mother Karin- in the State of New York;
and shds heir to Karin's estate and beneficiary of thdamily estate.
82. At all times hereinafter mentioned; Plaintiff G is a female and a minor.
83. At all .times hereafter mentioned, Plaintiff G is a Hispanic and American Indian.
84~

At all times hereafter mentioned, Plaintiff G is a victim of child abuse and domestic
violence-by Defendant CRANE.
STATE OF NEW JERSEY

85. Defendant STATE OF NEW JERSEY (hereinafter "STATE") is a State of the United
States ofAmerica.
86. At all times hereinafter mentioned, Defendant STATE OF NEW JERSEY is a RICO
Enterprise-with an ascertainable structure.
87. Defendant STATE is respondeat superior.
88. At all times mentioned herein, Defendant STATE OF NEW JERSEY is responsible for
the ESTATE OF RICHARD GARDNER because the theory of Parental Alienation
Syndrome (PAS) was born in in the S.tate of New Jersey.
89. At all times mentioned herein, Defendant STATE OF NEW JERSEY and the other
defendants are responsible for maintaining the nexus therefrom of discriminatory and
de facto policies against women and children, which has grossly affected domestic
relations law across the country and the world, interstate and global commerce, and
resulted in mail, wire, bank, and honest services fraud, child kidnapping, breach oftrust,
breach of fiduciary duty, deprivation of others' civil rights, inter alia.
90. At all times mentioned herein, Defendant STATE collected and received Federal
funding, employed, administered salaries, administered and managed retirement

15

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pensions, and collected monies through Title

IV~D,

the Fatherhood Initiative, and other

Federal funding directies and incentives,-to and on behalf of all STATE Defendants
named herein.
91. At all times-mentioned herein, defendants administered a de facto policy of sex-based
and status/class-based di!lcrimination against Plaintiff Karin Wolf because she is a
woman ,-mother, and domestic violence survivor; and against her children because they
are. victims of child abuse and the su!Jjects-of child custody litigation.
92. At all times mentioned herein, defendants administered a de facto policy of
status/class-based discrimination and punishment against Plaintiff Karin Wolf because
she was an unrepresented litigant and could not pay for attorneys, Guardians ad Litem,
and custody evaluators, etc.
93. At all times mentioned herein, defendants administered a de facto policy of
discrimination and punishment against Plaintiff Karin Wolf because she did not pay
bribes to the court and State officials.
94. Defendant STATE is responsible for ro!icies and customs and operated as a
governmental entity acting under C()lor of law, statutes, ordinances, regulations, public
policies, customs, and usages of STATE.
95. At all times mentioned herein, each Defendant employed as a alleged judge is
impersonating a State officer and public servant and is subject to the Tweel Fraud and
Cannine- Estoppel doctrines.
96. At all times mentioned herein, defendants acted towards Plaintiffs under color of law,
statutes, public policies, ordinances, customs, and usage of STATE and acted within

16

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and beyond the scope of their employment through intrinsic and extrinsic fraud. They
are sued in their individual and ufficial capacities.
97. At a:ii times mentioned herein, all Defendants are sued-for violating the Americans With
Disabilities Act.
98. At all times-mentioned herein, -all Defendants are sued for violating FOIA, OPRA, and

FERPA.
99. Under Title II of the Americans With Disabilities Ae~. there is no sovereign immunity.
CHRIS CHRISTIE
I 00. Defendant CHRIS cHRISTIE- (hereinafter "CHRISTIE") is Governor of the State of
New-Jersey and respondeat superior.
101. Defendant Christie is responsible for appointing judges and has abused his pewer.
102. Defendant CHRISTIE is responsible for the conduct of the STATE actors named
__herein, has failed to act, and has acted towards Plaintiffs under color of law, statutes,
public policies, ordinances, customs, and usage of the STATE and acted within and
beyond the scope. of his employment through intrinsic and extrinsic fraud.
103. He is sued in his individual and official capacities.
SUPERIOR COURT OF NEW JERSEY
104. Defendant SUPERIOR COURT OF NEW JERSEY (hereinafter "SCONJ") is the state
court in the U.S. State of New Jersey, witlr state-wide trial and appellate jurisdiction.
BERGEN COUNTY COURT
105. Defendant BERGEN COUNTY COURT (hereinafter "BERGEN COUNTY COURT")
is part of the Superior Court of New Jersey.

17

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106. At all times hereinafter mentioned, Defendant BERGEN COUNTY COURT is a RICO
"Enterprise with an aseertainable structure.
STUARTRA.BNER
107. Defendant STUART RABNER. (hereinafter "RABNER") is allegedly the "Chief
Justice"-of the Supreme Court Of New Jersey. He is sued in his individual and official
capacities.
108. Defendant RABNER is responsible for-reappointing Defendant GERALD C. ESCALA
to the bench for over four (4) years, despite the fact that Defendant ESCALA took a
bribe inlhe Denike v. Cupo case.
GERALD C. ESCALA
109. Defendant GERALD C. ESCALA (hereinafter "ESCALA") is an individual and alleged
retired "Judge" on recall for BERGEN COUNTY COURT. He is sued in his individual
and official capacities.
WILLIAM R. DELORENZO
110. Defendant WILLIAM R. DELORENZO (hereinafter "DELORENZO") is an individual
and alleged "Judge" (now retired) for the BERGEN COUNTY COURT. He is sued in
his individual and official capacities.
BONNIE J. MIZDOL
Ill. Defendant BONNIE J. MIZDOL (hereinafter "MIZDOL") is an individual and alleged
"Presiding Judge" (now "Assignment Judge") for BERGEN COUNTY COURT. She is
sued in her individual and official capacities.
PETERDOYNE

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112. Defendant PETER DOYNE (hereinafter "DOYNE") is an individual and alleged


"Assignme.nt Judge" (now retired) for BERGEN FAMILY COURT COURT. He is
sued in his individual and official capacities.
WILLIAM E. NUGENT
1I-3. Defendant WILLIAM E. NUGENT (hereinafter "NUGENT") is an individual and
alleged "Appellate Judge" for SCONJ. He is sued in his individual and official
capacities.
HARRY G. CARROLL
114. Defendant HARRY G. CARROLL (hereinafter "CARROLL") is an individual and
alleged "Appellate Judge" for SCONJ. He is sued in his individual and official
capacities.
ELLEN L. KOBLITZ
115. Defendant ELLEN L. KOBLITZ (hereinafter "KOBLITZ") is an individual and alleged
"Appellate Judge" for SCONJ. She is sued in her individual and official capacities.
JOHN C. KENNEDY
116. Defendant JOHN C. KENNEDY (hereinafter "KENNEDY") is an individual and
alleged "Appellate Judge" for SCONJ. He is sued in his individual and official
capacities.
JEROME M. ST. JOHN
117. Defendant JEROME M. ST. JOHN (hereinafter "ST. JOHN") is an individual and
alleged "Appellate Judge" for SCONJ. He is sued in his individual and official
capacities.
VICTOR ASHRAFI

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1 18. Defendant VICfOR ASHRAF! (hereinafter "ASHRAF!") is an individual and alleged


"Appellate Judge" forSCONJ. He is sued in his individual and official capacities.
JOSEPH L. YANNOITI
I 19. Defendant Judge JOSEPH L. YANNOTTI (hereinafter "YANNOITI") is an individual
and alleged "Appellate Judge" for SCONJ. He is sued in his individual and official
capacities.
ESTATE OF RICHARD GARDNER
120. Defendant ESTATE OF RICHARD GARDNER (hereinafter "GARDNER") is the
estate of a decedent located in or around Teaneck, NJ.
121. For purposes herein, it includes all teachings and materials written, published,
distributed, and otherwise administered, while he was alive and while he is deceased.
122. That at all times hereinafter mentioned, Defendant GARDNER is a RICO Enterprise
with an ascertainable structure.
123. Defendant GARDNER is responsible for creating the gross animus against women and
children by way of a theory called Parental Alienation Syndrome (PAS), based on
gender-biased, unscientific "studi.es."
ASSOCIATION OF FAMILY AND CONCILIATION COURTS
124. Defendant

ASSOCIATION

OF

FAMILY

AND

CONCILIATION

COURTS

(hereinafte-r "AFCC") is a non-profit organization headquartered at 6525 Grand Teton


Plaza, Madison, WI 53719. It has a chapter located in New Jersey known as NJ-AFCC.
125. At all times mentioned .herein, the headquarters and chapter shall be collectively known
as "AFCC."

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126. At all times hereinafter mentioned, Defendant AFCC is a RICO Enterprise with an
ascertainable structure.
127. At all times mentioned herein, Defendant AFCC is responsible for creating, teaching,
promoting, and administering the de facto policy of sex-based and status/class-based
discrimination against women, mothers, domestic violence victims in the family courts
of the United States of America and abroad.
128-. At all times mentioned herein, Defendant AFCC is responsible for creating, teaching,
promoting, and administering the de facto policy of sexual harassment, assault, battery,
child endangerment, and status/class-based discrimination against children and child
abuse victims in the family courts and alleged "child protective agencies" of the United
States of America and abroad.
129. At all times mentioned herein, Defendant AFCC is genemting hate crimes against
women and children.
NATIONAL FATHERHOOD INITlATIVE
130. Defendant NATIONAL FATHERHOOD INITIATIVE (hereinafter "FATHERHOOD
INITIATIVE") is a 501(c)(3) or 50l(c)(4) non-profit, non-partisan, non-sectarian
organization headquartered in Germantown, Maryland, founded on March 7, 1994.
131. At all times hereinafter mentioned, Defendant FATHERHOOD INITIATIVE is a RICO
Enterprise with an ascertainable structure.
!32. At all times mentioned herein, Defendant FATHERHOOD INITIATIVE is responsible
for creating, teaching, promoting, and administering the de facto policy of sex-based
and status/class-based discrimination against women, mothers, domestic violence
victims in the family courts of the United States of America and abroad.

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133. At all times mentioned herein, Defendant FATHERHOOD INITIATIVE is responsible


for creating, teaching, promoting, and administering the de facto policy of sexual
harassment, assault, battery, child -endanl!erment, and status/class-based discrimination
against children and child abuse victims in the family courts and alleged "child
protective agencies" of the United States of America and abroad.
134,_ At all times mentioned herein, Defendant FATHERHOOD INITIATIVE is generating
hate crimes against women and children.
NATIONAL PARENTS ORGANIZATION
135. Defendant NATIONAL PARENTS ORGANIZATION (herein included as part of the
"FATHERHOOD INITIATIVE"), until 2013 known as FATHERS & FAMILIES OR
FAMILIES AND FATHERS, is a 501(c)(3) or 501(c)(4) non-profit, charitable, and
educational organization founded in 1998, with amailing address of P.O. Box 270760,
Boston, Massachusetts 02127-0760.
OFFICE OF THE COUNTY COUNSEL
136. Defendant OFFICE OF THE COUNTY COUNSEL is a government office for Bergen
County located in Hackensack, NJ that serves as legal counsel to the County Executive,
the eight County Government departments, the Sheriff, the County Clerk, the Surrogate,
and the Prosecutor.
137. At all times mentioned herein, it is part of the RICO Enterprises named herein.
ADMINISTRATIVE OFFICE OF THE COURTS
138. Defendant ADMINISTRATIVE OFFICE OF THE COURTS (hereinafter "AOC") is a
government entity created and authoriied under the laws of the State of New Jersey.
139. It is sued as respondeat superior.

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140. At all times mentioned herein, it is part of the RICO Enterprises named herein.
GLENN GRANT
14LDefendant GLENN GRANT is..the head of.the AOC.
142. At all times mentioned herein, he is part of the RICO Enterprises named herein.
ADVISORY COMMITIEE ON JUDICIAL CONDUCf
143. Defendant ADVISORY COMMITIEE ON JUDICIAL CONDUCT (hereinafter
"ACJC") is a government entity created and authorized under the laws of the State of
New Jersey.
144. Defendant Advisory Committee on Judicial Conduct (ACJC) was and is at all times
herein a government entity created and authorized under the laws of the State of New
Jersey.
145. At all times mentioned herein, it is part of the RICO Enterprises named herein.
146. At al time mentioned herein, it is responsible to uphold ethics, address violations of
judicial ethics and judicial canons, and infringement of policies and customs.
147. It is operated as a governmental entity acting under the color of laws, statutes,
ordinances, regulations, policies, customs, and usages of the state of New Jersey.
148. It is sued as respondeat superior.
JOHN TONELLI
149. Defendant JOHN TONELLI is the head of the ACJC.
I 50. At all times mentioned herein, he is part of the RICO Enterprises named herein.
EDWARD CRANE
!51. Defendant EDWARD CRANE (hereinafter "CRANE") is an individual and Citizen of
the STATE OF NEW JERSEY.

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152. At all times mentioned herein, he is part of the RICO Enterprises named herein.
153. At all times mentioned herein, Defendant CRANE is a perpetrator of domestic violence
against Plaint{ff Karin Wolf and child abuse and endangerment against her children.
154. At all times mentioned herein, Defendant CRANE is illegally detaining Plaintiff Karin
Wolfs children and continues through present.
!55. At all times mentioned herein, defendants assisted CRANE in kidnapping and

f~lsely

imprisoning Plaintiff Karin Wolf's children, which continues through present.


156. At all times mentioned herein, Defendant CRANE has caused psychiatric injury to
Plaintiff Karin Wolf, which has manifested into PTSD.
157. At all times mentioned herein, Defendant CRANE has caused psychiatric injury to
Plaintiff Karin Wolf's children by brainwashing them against their mother- and
marginalizing their mother.
158. At all times mentioned herein, Defendant CRANE has caused the appearance that
Plaintiff Karin Wolf and her children have "Parental Alienation Syndrome" and that
that1s a real mental illness.
159. By doing so, Defendant CRANE has falsely represented to the Court, to the public, and
to others that Plaintiff Karin Wolf and her children are mentally ill.
160. He is sued for violating the Americans With Disabilities Act.
PETER VAN AULEN, ESQ.
161. Defendant PETER VAN AULEN, ESQ. (hereinafter "VAN AULEN") is an individual,
attorney, and member of the NEW JERSEY BAR ASSOCIATION conducting
substantial busir:ess in this District from offices located at 50 Market Street, Saddle
Brook, NJ 07663. He has also taught law at Seton Law University.

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162. At all times mentioned herein, he is part of the RICO Enterprises named herein.
163. At all times mentioned herein, Defendant VAN AULEN generated and administered a
de facto policy of sex-based and status/class-based discrimination against Plaintiff
Karin Wolf because she is a woman, mother, and domestic violence survivor; and
against her children because they are victims of child abuse.
164. At all times mentioned herein, Defendant VAN AULEN is responsible for-generating,
teaching, promoting, and administering the de facto policy of sex-based and
status/class-based discrimination against women, mothers, domestic violence victims in
the family courts of the United States of America and abroad.
165. At all times mentioned herein, Defendant VAN AULEN is responsible for generating,
teaching, promoting, and administering the de facto policy of sexual- harassment,
assault, battery, child endangerment, and status/class-based discrimination a_gJlinst
children and child abuse victims in the family courts and alleged "child protective
agencies" of the United States of America and abroad.
166. At all times mentioned herein, Defendant VAN AULEN is generating hate crimes
against women and children.
167. At all times mentioned herein, Defendant VAN AULEN has caused the appearance that
Plaintiff Karin Wolf and her children have "Parental Alienation Syndrome" and that
that is a-real mental illness.
168. By doing so, Defendant VAN AULEN has falsely represented to the Court, to the
public, and to others that Plaintiff Karin Wolf and her children are mentally ill.
169. He is sued for violating the Americans With Disabilities Act.
ALEXANDRA STREMLER, ESQ.

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170. Defendant ALEXANDRA STREMLER, ESQ. (hereinafter "STREMLER") is .an


individual, attorney, and member of the NEW JERSEY BAR ASSOCIATION
conducting substantial business in this District from offices formerly located at 250
Kinderkamack Road, Westwood, NJ 07675, now located at 198 Magnolia Avenue,
Hillsdale, NJ 07642.
171. At all times mentioned herein, she is part of the RICO Enterprises-named herein.
ROGER RADOL, ESQ.
172. Defendant ROGER RADOL, ESQ. (hereinafter "RADOL") is an individual, attorney,
and member of the NEW JERSEY BAR ASSOCIATION conducting substantial
business in this District from offices located at 15 Engle Street, Suite #102, Englewood,
NJ 07631.
173. At all times mentioned herein, he is part of the RICO Enterprises-named herein.
DR. JUDITH BROWN GREIF
174. Defendant DR. JUDITH BROWN GREIF (hereinafter "GREIF') is an individual and
New Jersey State licensed social worker and custody evaluator conducting substantial
business in this District, with offices located at 163 Engle St, Englewood, NJ 07631.
175. At all times mentioned herein, she is part of the RICO Enterprises named herein.
176. At all times mentioned herein, she is obligated to provide honest services to represent
children's best interests and the public interest and safety.
177. At all times mentioned herein, she is obligated to act consistent with her training and
pursuant-to social worker ethics.

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178. At all times mentioned herein, Defendant GREIF administered Richard -Q~rdner's
discriminatory policies against women and children for Parental Alienation Syndrome
(PAS) against Plaintiff Karin Wolf and her children.
179. At all times mentioned herein, Defendant GREIF persecuted and selectbrely prosecuted
Plaintiff Karin Wolf for Parental Alienation Syndrome solely-because Karin Wolf is a
mother.
180. At all times mentioned herein, Defendant GREIF falsely represented to Plaintiff Karin
Wolf that she would be conducting a fair and impartial custody evaluation,. thereby
creating a trust where Plaintiffs parted with details and information that GREIF twisted
and used against Plaintiffs, regardless of their merit.
181. At all times mentioned herein, Defendant GREIF blamed Plaintiff-Karin Wolf for being
a victim of domestic violence and reporting child abuse.
182. At all times mentioned herein, Defendant GREIF detained and interrogated Plaintiff
Karin Wolf and her children without reading them their Miranda rights.
183. At all times mentioned herein, Defendant GREIF accepted bribes from CRANE and
VAN AULEN to write a biased custody evaluation on behalf of Defendant CRANE and
falsely state that there was no domestic violence and child abuse by Defendant CRANE,
when in fact, there was.
184. At all times mentioned herein, Defendant GREIF testified in Court regarding Bergen
Family Center's custody evaluation when she had no authority to do so.
185. At all times mentioned herein, Defendant GREIF "cherry-picked" from Bergen Family
Center's custody evaluation and twisted the facts in Court against Plaintiffs.
186. At all times mentioned herein, Defendant GREIF perjured herself in Court.

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187. Defendant GREIF falsely purported that Plaintiff Karin Wolf has a psychiatric.illness,
in violation of the Americans with Disabilities Act~
188. GREIF intentionally aids and abets male litigants and the family courts of New Jersey

to marginalize mothers and enable child abuse, pornography, Tape, sodomy, and murder.
189. At all times mentioned herein, Defendant GREIF is responsible for generating,
teaching, promoting, and administering tlie de facto -policy of sex-based and
status/class-based discrimination against women, mothers, domestic violence victims in
the family courts of the United States of America and abroad.
190. At all times mentioned herein, Defendant GREIF is- responsible for generating,
teaching, promoting, and administering the de facto policy of sexual-harassment,
assault, battery, child endangerment, and status/class-based discrimination against
children and child abuse victims in the family i:ourts and alleged "child protective
agencies" of the United States of America and abmad.
191. At all times mentioned herein, Defendant GREIF is generating hate crimes against
women and children.
BERGEN FAMILY CENTER
192. Defendant BERGEN FAMILY CENTER (hereinafter "BFC") is an organization that
was and is at all times relevant herein an entity that operates on funds from the STATE
OF NEW JERSEY, Federal funding, other government grants, fees, and financial
contributions by professional organizations and private individuals.
193. At all times mentioned herein, it is part of the RICO Enterprises named herein.
194. At all times mentioned herein, it is obligated to act consistent with ethical standards,
policies and customs; and operated as a governmental entity acting under color of law,

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statutes, ordinances, regulations, public policies, customs-, and usages of the state of
New Jersey.
195. At all times mentioned herein, Defendant BFC acted, with intent to defraud, within and
beyond the scope of its duties as a forensic -evaluator appointed ll Defendants
BERGEN COUNTY COURT-and to be paid for by Plaintiff-Karin Wolf.
196. At all times mentioned herein, Defendant BERGEN FAMILY CENTER committed
fraud and false billing against Plaintiff Karin Wolf.
197. By way of example, BERGEN FAMILY CENTER billed Plaintiff Karin Wolf for
services that are already paid for by taxpayers.
198. By way of example, Defendant BFC represented to Plaintiff Karin- Wolf and her
children that it would conduGt a prudent custody evaluation when, in fact, it had no
intention of doing so.
199. By way of example, Defendant BERGEN FAMILY CENTER-discriminated against
Plaintiff Karin Wolf and her children; and punished them for non-payment by;
a) not conducting a complete and prudent custody evaluation
b) accepting bribes, directly and indirectly, from Defendant CRANE
c) reversing their original recommendations that custody should remain the status
quo with Plaintiff mother Karin Wolf to recommendations that custody should
go to Defendant CRANE
d) ignoring hard evidence against Defendant CRANE of child abuse

e) ignoring the terms of the Property Settlement Agreement dated May 22,2007

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f) lying to Plaintiff Karin Wolf thaLit-dl3es not evaluate financials, yet holding

Plaintiff Karin Wolf's diminished financiaL situation against her, when it wasclearly caused by Defendant CRANE and BERGEN-cOUNTY COURT
g) applying the pseudo-scientific theories of RICHARD GARDNER and de facto
policy of sex-based and statusfclass-based discrimination named herein to the
evaluations
h) ignoring sound-scientific studies by the lJ.S. Department of Justice, inter-alia.
200. It is sued for violating the Americans With Disabilities Act.
CONSTA!'lCE RITZLER
201. Defendant CONSTANCE RITZLER, I:.CSW (hereinafter "PJTZLER") is an individual
and resident of the State of New ;Jersey, domiciled in Bergen County and a New Jersey
State licensed-social worker and custody evaluator, employed by Bergen Family Center,
with offices located at 10 Banta Place, Hackensack, NJ 07601.
202. At all times mentioned herein, she is part of-the RICO Enterprises named herein.
203. At all times mentioned herein, she was under contract to conduct child custody
evaluations and obligated to represent children's best interests.
204. At all times mentioned herein, she is obligated to act consistent with her training and
pursuant to social worker ethics.
205. She is sued individually in that she acted beyond the scope of her duties as a forensic
evaluator and in her official capacity as an appointee of Defendants.
206. She is sued for violating the Americans With Disabilities Act.
JOHN CUTTITO

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207. Defendant JOHN -cU1TITO, LCSW (hereinafter "CUTTITO") is an inOividual- and


resident of the State ofNew Je~ey, domiciled in Bergen-County and a New Jersey State
licensed social worker and custody evaluator, employe1:l by Bergen Family Center as
Director of Clinical Services, with offices located at 10 Banta Place, Hackensack, NJ
07601.
208. At all times mentioned herein,_he is part ofthe RICO Enterprises named herein.
209. He is responsible for overseeing custody evaluations and obligated to represent
children's best interests.
210. At all times mentionedJierein, he is obligated to act consistent with his training and
pursuant to social worker ethies.
211. He is sued-individually in that he-acted beyond the scope of his position and duties and
in hi official capacity as an appointee of Defendants.
212. He is sued for violating the Americans WiLh Disabilities Act.
DIANA MOSKAL
213. Defendant DIANA MOSKAL (hereinafter "MOSKAL") is an individual and Family
Division Manager at Bergen County Court.
214. At all times mentioned herein, she is part of the RICO Enterprises named herein.
215. At all times mentioned herein, she is obligated to act consistent with her training and
pursuant to ethics, laws, statutes, ordinances, regulations, policies, customs, and usages
of the state of New Jersey.
216. She is sued individually in that she acted beyond the scope of her duties as Manager and
in her official capacity as an appointee of Defendants.
217. She is sued for violating the Americans With Disabilities Act.

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KATHY KATONA
218. DefendanCKATh' KATONA (hereinafter-"KATONA") is an-individual and Courtappointed Mediator at Bergen County Court.
219. At aii times mentioned herein, she is"j)art of the RICO Enterprises named herein.
220. At all times mentioned herein, she is obiigateo to act consistent with heLtraining and
pursuant to meaiator ethics, as well as laws, statutes, ordinances, regulations, policies,
customs, and usages of the state of New Jersey.
221. She is sued individually in -that she acted beyond the scope of her duties as Mediator
and in her _official capacity as an appointee of Defendants.
222. She failed to make accommodations-for Karin W()lf as a domestic violence victim with
-Post-Traumatic Stress Disorder (PTSD) and failed to report the abuse by Defendant
-CRANE towards Plaintiff Karin Wolf, which she personally witnessed during
mediation;
223. At all times mentioned herein, she breached trust and her fiduciary auty and committed
fraud in that she induced Plaintiff Karin Wolf -to divulge information which she used
against Plaintiff and directly caused Plaintiff to suffer severe emotional trauma and
distress, which caused further psychiatric injury to Plaintiff.
224. She put forth a falsehood that Plaintiff Karin Wolf is mentally ill when she had no
authority to make such a claim. In doing so, she gave the appearance of a disability in
Plaintiff Karin Wolf that does not exist.
225. She is sued for violating the Americans With Disabilities Act.
LISA ESTRIN

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22o. Defendant LISA ESTRIN, LCSW (hereinafter "ESTRIN")-is-an individual and resident

of the

~Late

of New Jersey, domiciled in Bergen County and a New Jersey State

licensed social worker and-conducting substantial business in this District,-with offiees


located .at 70 Hill to!) Rd~#l004, Kamsey, NJ 07446.
227. At all times mentioned herein, she-is part of the RICO Enterprises named herein.
228. At ali-times mentioned herein, she is obligated to act consistent with her training and
pursuant to mental health practitioner and social-worker ethics.
229. She is sued individually in that she acted beyond the scope of her authority and duties as
therapist to Plaintiff Karin Wolf's children.
230. She is sued in her official capacity because she violated ethics and breached her
-fiduciary duty, as she proceeded to treat Plaintiff Karin Wolf's children, illegally
authorized by Defendant CRANE while he shared joint legal custody of Karin Wolf's
children.
231. She is sued for brainwashing Plaintiff Karin Wolf's children against their mother.
232. She is sued for creating a psychiatric injury to Karin Wolf's children.
233. She is sued for violating the Americans With Disabilities Act.
DEPARTMENT OF HUMAN SERVICES/DEPARTMENT OF CHILDREN AND
FAMILIES/ DIVISION OF CHILD PROTECTION AND PERMANENCY
234. Defendant DEPARTMENT OF HUMAN SERVICES (hereinafter "DHS") is an
organization that was and is at all times relevant herein a governmental entity.
235. Defendant DEPARTMENT OF CHILDREN AND FAMILIES (hereinafter "DCF') is
an organization that was and is at all times relevant herein a governmental entity.

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236. Defendant DIVISION OF CHILD PROTECTION. AND PERMANENCY (hereinafter


"DCP&P") is an organiZ'dtion that was and-is-at all times relevant herein a governmental
entity. It is a subset of DCF.

23'1. At all times hereinafter mentioned, Defendant DHS, DCF, and DCP&P are a RICO
Enterprise with an asceminable structure.

138. All three are respondeat superior.


239. All-three are sued for maintaining a de facto policy of discrimination against Plaintiffs
as women and children.
240. All three are sued-for using Karin Wolf' s-and others' children as pawns to embezzle and
misappropriate f.ederal funding from Title IV -D and the Fatherhood Initiative.
241. All three are at all times obligated to act consistent with ethical standards, policies and
customs and operated as a governmental entities acting under the color of laws, statutes,
ordinances_, regulations, policies, customs, and usages of the state of New Jersey.
242. All three are sued for brainwashing Plaintiff Karin Wolf's children against their mother.
243. All three are sued for creating a psychiatric injury to Karin Wolf's children.
244. All three are sued for violating tbe Americans With Disabilities Act.
245. Defendant TARA HORNE (hereinafter "HORNE") is a social worker for DCP&P.
246. At all times mentioned herein, she is part of the RICO Enterprises named herein.
247. Defendant SANDRA CRUZ (hereinafter "CRUZ") is a social worker for DCP&P.
248. At all times mentioned herein, she is part of the-RICO Enterprises named herein.
249. Defendant PATRICK Y AN (hereinafter "YAN") is a social worker for DCP&P.
250. At all times mentioned herein, he is part of the RICO Enterprises named herein.
251. Defendant DEBBIE GOMEZ (hereinafter "GOMEZ") is a social worker for DCP&P.

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252. At alrtimes mentioned herein, she is part of the RICO Enterprises named herein.
253. Erica Frank (hereinafter "FRANK") is a social worker for DCP&P.
254. At all-times mentioned herein, she is part of the RICO Enterprises named herein.
255. DIGN:YS BtTRGOS-(hereinafter "BURGOS") is a social worker for DCP&P.
256. At all times mentioned herein, she is part of the RICO Enterprises named herein.
257;-IVAN NINA (hereinafter "NINA") is a social worker for DCP&P.
258. At all times mentioned herein, h-e is part of the RICO-Enterprises named herein.
25.9. At all times mentioned herein, each of them is obligated to act consistent with his or her
training and pursuant to social worker ethics, as well as laws, statutes, ordinances,
regulations, policies-, customs, and usages of the state of New Jersey.
260. Each of them is sued individually in that he or she acted beyond the scope of-his or her
duties as social worker and each in their official capacity as an employee of Defendants
DCP&P and the STATE.
261. Each of them is sued for brainwasl!ing Plaintiff Karin Wolfs children against their
mother.
262. Each of them is sued for creating a psychiatric injury to Karin Wolfs children.
263. Each of them is sued for violating the Americans With Disabilities Act.
FULL CIRCLE
264. Defendant FULL CIRCLE (hereinafter "FdLL CIRCLE") is a business entity located in
New Jersey that provides mental health counseling services, conducting substantial
business in this District, with offices located at 408 Main Street, Suite 203, Boonton, NJ

07005.

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265. It is an-appointee of Defendant DCP&P to brainwash Plaintiff Karin Wolf's children


against their mother ai!d has acted in concert with that appointment.
266. At-all times mentioned herein, it is part of the Rreo_Enterprises named herein.
'267. At all times mentioned herein, it is obligated to act consistent with its training and
pursuanno mental health practitioner and social worker ethics.
268. It is sued in that it acted beyond the scope of its authority and duties as a mental health
facility treating Plaintiffs D and G.
269. ft is sued for brainwashing Plaintiff Karin Wolf's children against their mother.

210. It is sued for creatil)g a psychiatric injury to Karin Wolfs children.


271. It is sue!lfor violating the Americans With Disabilities Act.
KRISTIN CIRELLI
272. Defendant KRISTIN CIRELLI, LCSW (hereinafter "CIRELLI") is a New Jersey State
licensed social worker employed by Defendant FULL CIRCLE.
273. She is an appointee of Defendant DCP&P to brainwash Plaintiff Karin Wolfs children
against their mother and has acted in concert with that appointment.
274. At all times mentioned herein, she is part of the RICO Enterprises named herein.
275. At all times mentioned herein, she is obligated to act consistent with her training and
pursuant to mental health practitioner and social worker ethics.
276. She is sued individually in that-she acted beyond the scope of her authority and duties as
therapist to Plaintiffs D and G.
277. She is sued for brainwashing Plaintiff Karin Wolf's children against their mother.
278. She is sued for creating a psychiatric injury to Karin Wolf's children.
279. She is sued for violating the Americans With Disabillties Act.

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BETH LAFORGIA
280. Defendant-BETH LAFORGIA, LCSW (hereinafter "LAFORGIA") is a New Jersey
State licensed mental health practitioner-.
281.-She is an appointee of Defendant DC:P&P to brainwash Plaintiff Karin Wolfs children
against their mother and has acted in concert with that appointment.
282. At all times mentioned herein, she is part of the RICO Enterprises named herein.
283. At all times mentioned-herein,_she is obligated to act consistent with her training and
pursuant to mental health practitioner and social w_orker ethics.
284. She is sued individually in that she acted beyond the scope of her authority and duties as
therapist to Plaintiffs D and G.
285. She is sued for brainwashing Plaintiff Karin Wolf's children against their mother.
286. She is sued for creating a psychiatric injury to Karin Wolf's children.
287. She is sued for violating the Americans With Disabilities Act.
ATIORNEY GENERAL OF THE STATE OF NEW JERSEY
288. Defendant ATTORNEY GENERAL OF THE STA:TE OF NEW JERSEY (hereinafter
"AG-NJ") is at aJl times herein a government entity created and authorized under the
laws of the State of New Jersey.
289. At all times mentioned herein, it is part of the RICO Enterprises named herein.
290. It is responsible to uphold ethics; address violations and infringement of policies and
customs; and pmtect the civil rights of the constituents and visitors of the State of New
Jersey, pursuant to its Mission Statement.
291. It operates as a government entity, acting under the color of laws, sta1ates, ordinances,
regulations, policies, customs, and usages of the state of New Jersey.

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292. It is sued in that it acted beyond the scope of its responsibilities and failed to act
,uursuant to its responsibilities.
293. By way of example, it has-defended STATE employed-defendants here__and violated
public interest and public-safety in doing so.
294. By way of example, it has defended and continues to defend said defendants as they are
sued in their individual capacities herein. In doing so, it is misusing taxpayer dollars and
violating the public's trust.
295. It is sued for false advertising, fraud, and breach of trust.
GOOD SHEPHERD LUTHERAN CHURCH
296. Defendant G00D

SHEPHERD

LUTHERAN

CHURCH (hereinafter "GOOD

SHEPHERD") is a church and religious organization located at 233 S. Highwood


Avenue, Glen Rock, NJ 07452.
297. At all times mentioned herein, it is part of the RICO Enterprises named herein.
298. She is sued. for aiding- and abetting Defendant CRANE in distributing bribes to judges
and public officials named herein, througii mail, wire, and bank fraud.
299. It is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolf's children.
300. It is sued for administering religious ceremonies and educating Plaintiff Karin Wolf's
children against Plaintiff's wishes and the terms of the Property-Settlement Agreement.
301. It is sued for brainwashing Plaintiff Karin Wolf's children against their mother.
302. It is sued for abusing Plaintiff Karin Wolf's children.
303. It is sued for trespassing upon Plaintiff Karin Wolf's estate a,!d property.
3D4. It is sued for obstructing justice.

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305. It is sued for violating the Americans With Disabilities Act.


306. It is sued for violating the Freedom of Information Act (FOIA), Open Public Records
Act (OPRA), and-Family Educational Rights and Privacy Act (FERPA).
REVEREND DR. ROGER W. SPENCER
307. Defendant REVEREND DR. ROGER W. SPENCER (hereinafter "SPENCER") is an
individual and was head pastor at Defendant GOOD SHEPHERD during the events
mentioned herein.
308. At all times mentioned herein, he is part of the RICO Enterprises named herein.
309. He is sued for aiding and abetting Defendant CRANE in distributing bribes to judges
and-public officials named herein, through mail, wire, and bank fraud.
310. He is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolf's children.
31!. He is sued-for administering religious ceremonies and educating Plaintiff Karin Wolf's
children against Plaintiff's wishes and the terms of the Property Settlement Agreement.
312. He is sued for brainwashing Plaintiff Karin Wolf's children against their mother.
313. He is sued for abusing Plaintiff Karin Wolf's children.
314. He is sued for trespassing upon Plaintiff Karin Wolf's estate and property.
315. He is sued for obstructing justice.
316. He is sued for violating the Americans With Disabilities Act.
317. He is sued for violating the Freedom of Information Act (FOIA), Open Public Records
Act (OPRA);and Family Educational Rights and Privacy Act {FERPA).
JANET TENC\RE

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318. Defendant JANET TENORE (hereinafter ''TENORE") is an individual and works as the
church secretary for Defendant GOOD SHEPHERD.
319. At all-times mentioned herein, she-is parLof the RICO Enterprises named herein.
320. -sh~ is sued for aiding and abetting Defendant CRANE in distributing bribes to judges
and public officials named herein, through mail, wire, and bank fraud.
321. She is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolf's children.
322. She is sued for administering religious ceremonies and educating Plaintiff Karin Wolf's
children against Plaintiff's wishes and the terms of the Property Settlement Agreement.
323. She is sued for brainwashing-Plaintiff Karin Wolf's children against their mother.
324. She is sued for abusing_p!aintiff Karin Wolf's children.
325. She is sued for trespassing upon Plaintiff Karin Wolf's estate and property.
326. She is sued for obstructing justice.
327 . .She is sued for violating the Americans With Disabilities Act.
328. She is sued for violating the Freedom of Information Act (FOIA), Open Public Records
Act (OPRA), and Family Educational Rights and Privacy Act (FERPA).
329. At all times herein where GOOD SHEPHERD is stated, it shall refer collectively to
Good Shepherd Lutheran Church, The Reverend Roger W. Spencer, and Janet Tenore.
LUCIANA COUTINHO-CRANE
330. Defendant LUCIANA COUTINHO-CRANE (hereinafter "LU") is an individual and
resident of the State of New Jersey, domiciled in Bergen County in Glen Rock, NJ and
has possible alternate residence in the \-:ountry of Brazil.

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331. Defendant LU meets the minimum contacts in this jurisdiction and because her offenses
in the events giving rise to this action occurred within the Newark District.
332. She is sued for aiding and abetting Defendant CRANE in distributing bribes tojudges
and public officials named herein, through mail, wire, and bank fraud.
333. She is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolfs children.
334. She is sued for abusing Plaintiff Karin Wolf's children.
335. She is sued for trespassing upon Plaintiff Karin Wolf's estate and property.
336. She is sued for obstructing justice.
337. She is sued for violating the Americans With Disabilities Act.
MARLENI COUTINHO
338. Defendant MARLENI COUTINHO (hereinafter "MARLENI") is an individual and
resident of the State of New Jersey, domiciled in Bergen County in Glen Rock, NJ and
has alternate residence in the Country of Brazil.
339. Defendant MARLENI meets the minimum contacts in this jurisdiction and because her
offenses in the events giving rise to this action occurred within the Newark District.
340. She is sued for aiding and abetting Defendant CRANE in distributing bribes to judges
and public officials named herein, through mail, wire, and bank fraud.
341. She is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolfs children.
342. She is sued for abusing Plaintiff Karin Wolfs children.
343. She is sued for trespassing n;>on Plaintiff Karin Wolfs estate and property.
344. She is sued for obstructing justice.

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Pag~ID:

3A5. She is sued for violating the Americans With Disabilities Act.
PLINIO COUTINHO
346. Defendant PLINIO COUTINHO (hereinafter "PLINIO") is an individual and resident
of the State of New Jersey, domiciled in Bergen County in Glen Rock, NJ ilnd has
alternate residence in the Country of Brazil.
347. Defendant PLINIO meets the minimum contacts in this-jurisdiction and because his
offenses in the events giving rise to this action occurred within the Newark District.
348. He is sued for aiding and abetting Defendant CRANE in distributing bribes to judges
and public officials named herein, through mail, wire, and bank fraud.
349. He is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolf's children.
350. He is sued for abusing Plaintiff Karin Wolf's children.
351. He is sued for trespassing upon Plaintiff Karin Wolf's estate and property.
352. He is sued for obstructing justice.
353. He is sued for violating the Americans With Disabilities Act.
GLEN ROCK SCHOOL DISTRICT
354. Defendant GLEN ROCK BOARD OF EDUCATION (hereinafter " GR BOARD OF
ED") is located at 620 Harristown Road, Glen Rock, NJ 07452.
355. Defendant GLEN ROCK MIDDLE SCHOOL (hereinafter "GR MIDDLE SCHOOL")
is a school located at 600 Harristown Road, Glen Rock, NJ 07452.
356. Defendant EDWARD THOMPSON (hereinafter "THOMPSON") is the Principal of
GLEN ROCK MIDDLE SCHOOL.

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357. He is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolf's children.
358. He-is sued_for trespassing upon Plaintiff Karin Wolf's estate and property.
359. He is sued for obstructing justice.
360. He is sued for falsely imprisoning Plaintiff Karin Wolf and her children.
361. He is sued for brainwashing Plaintiff Karin Wolf's children.
362. He is sued for abusing Plaintiff Karin Wolf's children.
363. He is sued for violating the Americans With Disabilities Act.
364. He is sued for violating the Freedom of Information Act (FOIA), Open Public Records
Act (OPRA), and Family Educational Rights and Privacy Act (FERPA).
365. Defendant BRIAN PEPE (hereinafter "PEPE") is the Vice-Principal of-GLEN ROCK
MIDDLE SCHOOL.
366. He is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolf's children.
367. He is sued for trespassing upon Plaintiff Karin Wolf's estate and property.
368. He is sued for obstructing justice.
369. He is sued for falsely imprisoning Plaintiff Karin Wolf and her children.
370. He is sued for brainwashing Plaintiff Karin Wolf's children.
371. He is sued for abusing Plaintiff Karin Wolf's children.
372. He is sued for violating the Americans With Disabilities Act.
373. He is sued for violating the Freedom of Inf<Jrmation Act (FOIA), Open Public Records
Act (OPRA), and Family Educational Rights and Privacy Act (FERPA).
GLEN ROCK POLICE DEPARTMENT

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374. Defendant GLEN ROCK POLICE DEPARTMENT (hereinafter "GRPD") is located-at


1 Harding Plaza, Glen Rock, NJ 07452.
375. It is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolfs children.

376. It is sued for trespassing upon Plaintiff Karin Wolf's estate and property.
377. It is sued for obstructing justice.
378. It is sued for falsely imprisoning Plaintiff Karin Wolf and her children.

379. It is sued for failing to read Plaintiff Karin Wolf her Miranda rights.
380. It is sued for abusing Plaintiff Karin Wolf's children.
381. It is sued for violating the Americans With Disabilities Act.
382. It is sued for violating the Freedom of Information Act (FOIA),_OQen Public Records
Act (OPRA), and Family Educational Rights and Privacy Act (FERPA).
BERGEN COUNTY SHERJFF
383. Defendant BERGEN COUNTY SHERJFF (hereinafter "BC SHERIFF') is located at
160 S River St, Hackensack, NJ 07601.
384. It is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolf's .children.

385. It is sued for trespassing upon Plaintiff Karin Wolf's estate and property.
386, It is sued for obstructing justice.
387. It is sued for violating the Americans With Disabilities Act.
388. It is sued for violating the Freedom of Information Act (FOIA), Open Public Records
Act (OPRA), and Family Educational Rights and Privacy Act (FERPA).
NEW JERSEY STATE BAR ASSOCIATION

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389. Defendant NEW JERSEY STATE BAR ASSOCIATION (hereinafter "NJBAR") is


located at 1 Constitution Square, New Brunswick, NJ 08901.
390. At all times mentioned herein, the NEW JERSEY STATE BAR ASSOCIATION is a
RICO Enterprise with an ascertainable structure.
391. It is sued for administering a de facto policy of discrimination-against prose and other
unrepresented litigants in the Courts of New Jersey in that they are-treated with
contem)Jt and do not receive justice unless they pay for-it.
392. Said de facto policy injured Plaintiffs as a result.
393. It is sued for aiding and abetting Defendant CRANE in kidnapping Plaintiff Karin
Wolfs children.

394. It is sued for trespassing upon Plaintiff Karin Wolf'-s estate and property.
395. It is sued for obstructing justice.
396. It is sued for falsely imprisoning Plaintiff Karin Wolf and her children.

397. It is sued for abusing Plaintiff Karin Wolf's children.


398. It is sued for violating the Americans With Disabilities Act.
399. It is sued for violating the Freedom of Information Act (FOIA), Open Public Records
Act (OPRA), and Family Educational Rights and Privacy Act (FERPA).

400. That the NJBAR persecutes litigants according to economic status; its agents in the
legal community use extortion, coercion, and threats that litigants will not receive
justice if they do not pay for it, either by legal fees or bribing judges.
401. By way of example, Rachel Alintoff and Plaintiff Karin Wolf have contacted over 40
attorneys to represent themselves and their minor children to no avail because all have
said in one manner or another that it would be "career suicide" to go against the same

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judges whom they must appear before and would -face ostracism !i:ii(hetaliation in the
legal community.
402. By way of example, several women report they are under threat to be dropped by their

own attorneys if they join Rachel Alintoff or Karin Wolf in this-!it1gation; and-that they
have been nudged to bribe judges.
403. Moreover, Legal Aid is

a-fa~ade

and at conflict-with the maxims of eguity, as there are

no sliding scale fees to legal representation.


404. This is a block to justice by the NJBAR, CHRISTIE, NJ ATIORNEY GENERAL, and

STATE to constructively deprive Citizens of their rights under color of law.


BANK OF AMERICA/MERRILL LYNCH
405. Defendant BANK OF AMERICA/MERRILL LYNCH (hereinafter "BANK OF

AMERICA") is a Delaware corporation with its principal place of business in Charlotte,


North Carolina and offices and branches in New York, NY.
406. Defendant BANK OF AMERICA employs Defendant CRANE as an executive in New

York City.
407. It is sued for using family court proceedings in conjunction with the other defendants as

insiders to deprive others of their real estate and other property by driving them to
foreclosure and bankruptcy; and bribing judges and court officials.
DOES
408. Defendant DOES are "Father's Rights" and "Men's Rights" activists perpetrating hate

crimes and deprivations of law and rights against women and children.
409. Defendant DOES are policymaking officials of Defendant STATE and individuals in

the banking and securities industries, who are as responsible as the other named

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Defendants in this action and who knew of and ignored -tlre constitutional violations in
this case and in other cases which they have for years reinforced a custom and policy in
the Family Court of ignoring litigants' due process rights; discriminating against
women and children; and engaging in racketeering and" bankingJratid", inter alia.
410. Plaintiffs reserve thenghtto-amend"and-reinstate all claims in this Complaint and the
original Complaint after discovery reveals the true names of DOES and as more
information becomes available as-to the extent of the injuries suffered by Plaintiff Karin
Wolf and her children.
411. Plaintiffs bring this action to vindicate their federal constitutional and international Civil
rights in the New Jersey State Courts.
412. Plaintiffs bring this action to-declare all orders of the BERGEN COUNTY COURT
void for lack of subject matter jurisdiction, inter alia stated herein.
413. Plaintiff Karin Wolf complains pursuant to the laws of the United States of America,
seeking damages to redress the injuries Plaintiff is inflicted with_ as a result of being
deprived of due process, selectively prosecuted in quasi-criminal proceedings under the
color of civil law, sexually harassed, discriminated against, falsely imprisoned, and
retaliated against by the Defendants on the basis of her gender/sex, status/class as
mother, and ethnicity/race as Hispanic/American Indian; and disability/class as a
domestic violence survivor with Post-Traumatic Stress Disorder (PTSD) and Battered
Women's Syndrome (BWS), in violation of the Americans With Disabilities Act.
414. Likewise, Plaintiffs D and G hereby make claim that they are being discriminated
against by the Defendants based on their status/class as children, ethnicity/race as

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Hispanic/American Indian, and

disabilitv/class~as

child abuse victims, in violation of

the American With Disabilities Act.

415. Plaintiffs Karin, D, and G complain of the Defendants-engaging in a pattern of


racketeering activity via sex-based, status/class-based,

ethnicity/race~based,

and

disability-based discrimination-in violation of the Equal Protection Clause of the 14th


Amendment of the United States Constitution; the Civil Rights Act of 1964 - Public
Law 88-352 (78 Stat. 241 ).

416. Plaintiffs are targeted for selective prosecution in the NJ family court proceedings, as
those proceedings are arbitrari-ly decided and de facto criminal, or quasi-criminal.
417. Selective prosecution is a violation of t.he constitutional guarantee of equal protection
for all persons under the law. On the federal level, the requirement of equal protection is
contained-in the. due process clause of the Fifth Amendment to the U.S. Constitution.
The Equal Protection Clause of the Fourteenth Amendment extends the prohibition on
selective prosecution to the states. The equaLprotection doctrine requires that persons in
similar circumstances must receive similar treatment under the law.

418. At all times herein, this body of discrimination is a purpose of all named RICO
Enterprises.
419. At all times herein, this body of discrimination is a factor of ascertainable structure of
those Enterprises.
420. At all times herein, personal enrichment is a purpose of all named RICO Enterprises.
421. At all times herein, personal enrichment is a factor of ascertainable structure of those
Enterprises.

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422. Plaintiffs complain of the defendants-engaging in a pattern of racketeering activity- via


breaching the public trust, moral and legal norms.
423. Plaintiffs complain of the Defendants engagingin a pattern uf racketeering activity by
manifesting and administering_a_de factopubhc-policy contrary model codes, common
sense and sound scientific principles; and reports by the _U.S-. Department of Justice (i.e.
Saunders-Report on domestic violence and-child custody).
424. At all times herein, detriment of public interest is a purpose of all named RICO
Enterprises.
425. At all times herein, detriment of- public interest is 11 factor of 1rscertainable structure of
those Enterprises.
426. Upon complaining about the oeprivation of due process, illegal activities, sexual
harassment,. the hostile environment, and the discrimination, Plaintiffs were subjected to
retaliation with further discrimination and hostilities resulting in their constructive
deprivation of rights, loss of society, and damage to property.
427. At all times herein, Defendants are engaging in a pattern of racketeering activity by
acquiring money and property by Embezzlement, Larceny, Fraud, Extortion, Coercion,
Bribery, and Domestic Terrorism, inter alia.
Defendants Who Purport To Be Judges Are Barred by Estoppel
428. State judges are required by Article VI, Clause 3 of the United States Constitution and4
USC 101 to take an Oath of Office swearing to uphold the United States Constitution.
429. Plaintiff Karin Wolf presented all alleged judges named as Defendants herein with a
Notice and Demand for Exhibition of Oath of Office by U.S. Mail on February 21,
2015.

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430. All defendants alleged as-judges failed to provide proof of Oath of Office-in violation of
the Open Public Reeords Act (OPRA) and the-Freedom of Information Act (FOIA).
Miranda Warning. Tweei-Fraud and Carmine Estoppel Doctrines
431. At ali-times mentioned herein, each-defendant impersonating a State.officer is subject to
fine and/or imprisonment for up to three years_pursuant to 18 USC 912.
432-. At -all times -mentioned herein, each named Defendant employed as a judge is
committing mail fraud pursuant to 18 usc-1341.
433. Under the auspices_of conducting a civil examination in the "best interests of the
children," defendants-as named herein working for the STATE OF NEW JERSEY acted
under color law to conduct what was in reality a criminal or quasi-criminal investigation
of Plaintiff-Karin Wolf-because she is a woman and a mother.
434. Though Karin Wolf was the original Plaintiff, she was a de facto Defendant in the
family proceedings that commenced in March 2010 and again in February 2011.
435. Defendants manufactured false allegations of psychiatric deficiencies in Plaintiff
because she is a woman, mother, and domestic violence victim.
436. Defendants manufactured false allegations of psychiatric deficiencies in the minor
children because they are victims of child abuse by Defendant CRANE.
437. By way of example, Defendants accused Plaintiff Karin Wolf of "alienating the
children" from Defendant CRANE and that the children had Parental Alienation
Syndrome.
438. The children are afraid of Defendant CRANE because he abuses them.
439. Defendants are victim-blaming and persecuting Plaintiffs.

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440. As a result, Plaintiff lost residential and legal custody of her_children in August 2013
(and was-later barred from contact with them).
441. Simultaneously, the BERGEN COUN1'Y COURT did not make any provisiuns -to
remedy these so-called "psychiatric defidencies," which is a violation of the
. Americans Wilh Disabilities Act because they are mandated to do so under the Act.
442. SaiODefendants failed to provide Notice of Rights to Plaintiff Karin Wolf pursuant to

Miranda v. Ariwna, 384 U.S. 43&(1966) throughout the interrogations.


443. Such actions violate public policies established by State and Federal Law, policies the
violation of which allegedly implicate the-Plaintiff's rights to due process of law.
444. The referral by the State-employed Defendants to and the subsequent civil examination
by Defendants DR. JUDITH BROWN GREIF and BERGEN FAMILY CENTER
constitute an elaborate ruse by which the Defendants sought to deceive the Plaintiff
mother into cooperating with what all along was a criminal investigation, conduct
which would violate her 4'h Amendment rights.
Americans With Disabilities Act
445. Defendants' goal is to segregate the children from their mother because she is a
woman, mother, and domestic violence victim.
446. Defendants' goal is to "gaslight" the children.
447. Defendants are committing hate crimes against Karin Wolf and all women.
448. Defendants are committing hate crimes against the children.D and G.
449. Defendants CRANE and STATE employed Defendants named herein collude to force
Plaintiff Karin Wolfs children to conditioning therapy where Defendants GREIF,
BERGEN FAMILY CENTER, CIRELLI, FULL-CIRCLE, BETH LAFORGIA, LISA

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ESIRIN program the children to hate women and mothers, and b extension
-themselves.
450: Defendants are-using the children as experiments akin to Harlow's Rh-e-sus-monkeys.
451. By way of example, defendants segregated the-children from their mother.
452. By way of example, defendants are depriving the children from their mother's warmth.

453. By way-of-example, defendants plant false memories in the children's heads.


454. By -way of example, defendants lie 10 the children saying their mother doesn't want

them.
455. -By way of-example, defendants make the children feel guilt and shame for loving their

mother and w11nting to be with her.


456. -By way of example, defendants are panic-striking the children by threatening they will

never see their mother again and that she-is dead.


The Court Cannot Dismiss This Case
457. Civil RICO claims need only prove a preponderance of evidence.
458. Plaintiffs are entitled to relief and this case must proceed because civil RICO is held to

less stringent standards than criminal RICO.


459. This action raises matters of fact and is for a jury of the people to decide.
460. To deny parties the right to adjudicate this matter in a trial by jury will result in a gross

miscarriage of justice here.


46L This Court has a duty of care to the Republic of the People of the United States of

America.
This Court Has Authority To Hear This Matter

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462. This Court has the authority to hear-this matter because the -amount- in controversy
exceeds the sum or value of $75~000. exclusive of interests and costs, this matter is
between citizens of different States.
463. This Court has the authority to hear this matter because the Defendants violated the
Constitution of the United States of America.
464.-This Court has the authority to hear this matter because the Defendants violated Federal
Law.
465. This Court has authority to hear this matter because certain J)efendants-infringed upon
Plaintiffs' Right to Freedom of Mov-ement pursuant to the Privileges and Immunities
Clause. of the Constitution of the United States of America, Article IV, Section 2,
Clause 1.
466. This Court has authority to hear this matter because the pleadings herein raise a Federal
qJJestion as to the constitutionality, pursuant to FRCP 5.1, of the STATE OF NEW
JERSEY's infringement upon Plaintiff Karin Wolf's contractual rights of the Property
Settlement Agreement dated May 22,2007, which contained bargained-for terms.
467. Said agreement was an irrevocable trust.
468. Said agreement designated the minor children as property and beneficiaries; and Karin
Wolf (nee Crane) as Primary Trustee and Conservatrix (Administrator).
469. Defendants administered a de facto

gender~biased

policy against Karin Wolf here.

470. That there is a de facto policy of segregating mothers and children in the family courts
and that this policy is masquerading as providing separate but equal treatment of both
mothers and fathers as the "best interests of the child standard" and FATHERHOOD
INITIATIVE.

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-471. There is a tle facto policy of placing children who are_ victims of child abuse with their
abusers in the family cgurts and that this policy is masquerading as the "best interests of
thechikl standard" and FATHERHOOD INITIA'I'IVE.
472. There is a-de facto policy of forcing and falsely imprisoning domestic violence victims
into continued direct contact with their abusers and denying restraining orders based on
prejudice that all women are liars when they complain of abuse in the family courta.
473. There is

ade facto p0licy of forcing and falsely imprisoning domestic violence victims

into continued direct contact with their abusers and denying restraining orders based on
prejudice-that all women are liars when they complain of abuse in the family courta.
474. Plaintiff Karin Wolf challenges the STATE lack of a statute that automatically appoints
a lawyer for any child in the family courts.
475. This Court has the authority to hear this matter because the Defendants violated the
International Covenant On Civil And Political Rights Treaty, to which the United States
of America is a party.
476. This Court has. the authority to hear this matter because the Defendants violated the
United States Reservations, Understandings, and Declarations to The International
Covenant On Civil And Political Rights Treaty.
477. This Court has the authority to hear this matter because the Defendants violated the
Universal Declaration Of Huinan Rights Treaty, to which the United States of America
is a party.
478. This Court has the authority to hear this matter because the Defendants violated the
Hague Treaty, to which the United States of America is a party.

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479:-This Court-has the authority to hear this matter because it is a well-established law that
a void order-can be attacked at any time, in any court, in any proceeding,_either directly
or collaterally.
480. That at all times mentioned herein each Defendant was the agent, associate, affiliate, coconspirator, superior, and /or employee of each other defendant and was acting within
the course, scope, and purpose of such relationship in each ascribes of them herein,
except as{)therwise alleged.
481. That at all times set forth by the averments herein where Plaintiffs allege that any
Defendant has perpetuated and/or continues to perpetuate a pattern of collusion,
conspiracy, scheming, fraud, extortion, witness tampering, retaliation, abuse,
harassment, tortious interference, tortious acts, intentional infliction of emotional
distress, personal injury, kidnapping, false imprisonment, obstruction of justice,
constitutional violations, ethical violations, violations of public policy and codes of
conduct, indecency, engaged in-or aided and abetted a pattern of racketeering activity,
was part of a RICO ENTERPRISE in violation of federal and state law, and/or
otherwise committed a violation of law, either statutory or common, federal or state, it
shall constitute a predicate act in each instance pursuant to 18 USC 1961 and define
state actors as having acted under color of law, acted beyond the scope of their
employment and official capacity, for personal gain or pleasure, acted beyond the scope
of their responsibilities and/or failed to act pursuant to their responsibilities.
482. That all claims and causes of action herein are not barred by sovereign or judicial
immunity, Rooker -Feldnum, or Stump v. Sparkman because the DefenJants committed

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extrinsic fraud; sex-based, status-based, ethnicity/race-based and disability-based


discrimination.
483. All STATE actors named

he.r~in

stepped out of the boundS-of that immunity once they

committed fraud and treasen; and that the legal maxim, "Equity will not allow a statute
to be used as a cloak for fraud" shall prevail here.
484. Plaintiff Karin Wolfs biological issue, beneficiaries, and heirs D and G are listed in the
l'roperty Settlement Agreement dated May 22, 2007.
485. Plaintiff Karin Wolf is the sole owner of the titles known as the Certificate of Live Birth
of herself, D, and G.
486. The Property Settlement Agreement is now void by sworn affidavit with jurat.
487~

Plaintiffs and Real Parties in Interest Karin, D, and G are property in that their bodies
are landed estates as set forth by the Holy Bible in Genesis 3:19, declared by Congress
at Public Law 97-280,% stat 1211, Oct 41982 and Executive Order 6100 of Sept 22,
1990.-

488. Defendants damaged the Plaintiffs' estate.


489. Defendants damaged Plaintiffs' .property.
490. Defendants damaged Plaintiff Karin Wolf in her business.
491. Plaintiffs/Beneficiaries D and G complain that Defendant CRANE physically and
emotionaH)' .abuses them.
492. Plaintiffs D, age 13, and G, age 11 li, complain that they have been denied their due
process right to have a voice in the Court and demand to be meaningfully heard.
493. Plaintiffs D and G complain that they are being held from the:r mother against their will
and falsely imprisoned.

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494. Plaintiffs D and G complainJhat they are being forced into anti-mother reconditioning
therapy by Defendants DCP&P, CRANE, KRISTIN CIRELLI, FULL CIRCLE, LISA
ESTRIN, BETH-bAFORGIA, BERGEN COUN"TY COURT, and the STATE OF NEW
JERSEY.
495. Plaintiff Karin Wolf complains that Defendants DCF-DCP&P, CRANE, ORELLI,
FULL CIRCLE, ESTRIN, LAFORGIA, BERGEN COUNTY COURT, and the STATE
oF NEW JERSEY are poisoning the minds of her children against her based on her
gender/sex and status as their mother.
496. Plaintiff Karin Wolf complains that D and G have not been returned to her, in violation
of her-fundamental rights as a parent.
497. Plaintiff Karin Wolf complains that D and G are being held hostage by defendants
CRANE and the STATE OF NEW JERSEY.
De Facto Public Policy of Discrimination of Women, Mothers. and Victims of Abuse
498. At all times- mentioned herein, defendants discriminated against Plaintiff Karin Wolf
and her children and conspired-to deprive them of their rights by the following:
499. Defendant GARDNER created a theory called Parental Alienation Syndrome (PAS)
based on gender-biased, unscientific "studies" against mothers.
500. It has no basis in fact.
50LThe theory of Parental Alienation Syndrome (PAS) is commonly used as a redirect for
males in the family court system, who are abusers and sexual predators, to blame their
victims and wrestle child custody away from protective mothers.
502. It aims at destroying the credibility of women.
503. Defendant GARDNER falsified the theory that mothers are alienating parents.

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504. Defendant GARDNER promoted child sexual abuse.


505. Defendant GARDNER is not a credible witness.
506. DefendanLGARDNER perjured himself in-over 400 .custody cases.

507. The American Psychological Association has rejected Defendant GARDNER's theories
of Parental Alienation Syndrome with each version of the Diagnostic and Statistical
Manual of Mental Disorders (DSM-Siatest edition).
508. The purpose of Parental Alienation is to pathologize female and child victims,
marginalize protective mothers; subvert, enable, and cover up child abuse; and terrorize,
oppress, and humiliate women and children through "witch hunt" tactics.

509. It is an "end goal" rather than the cause and effect it purports to be. Its purpose is to
remove the mother from her children's lives, as she is a roadblock to those who seek to
abuse her child.
510. The detrimental effects of maternal deprivation are recognized by Harry Harlow's
studies as referenced herein and the Center for Disease Control ;s study on Adverse
Childhood Experiences (ACE study).
511. Maternal Deprivation is included in the DSM and is a factor of Anti-Social Personality
Disorder (DSM IV 301.70), which produces sociopaths.
512. Signs and symptoms include:

Lack of concern regarding society's rules and expectations.

Repeated violations of the rights of others.

Unlawful behavior (namely murder and rape).

Lack of regard for the truth.

In parents, neglect or abuse of children.

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Lack of a steady job. Frequent job changes through quitting and/or being fired .

Tendencies toward physical aggression and extreme irritability.

Alcohol and drug abuse.

513. Defendants purported and continue to purport that Plaintiff Karin Wolf and her children
have a "mental disorder" known as Parental Alienation Syndrome in violation of the
Americans with Disabilities Act.
5I4. Plaintiff Karin Wolf hereby reserves the right to sue and/or reinstate all claims herein if
any of the following events occur:

One or both of her children are diagnosed with a mental disorder(s)

One or both of her children are diagnosed with depression

One or both of her children commit suicide

Her daughter becomes pregnant before the age of I 8

Her son impregnates a girl before he reaches the age of I8, or impregnates a girl
under the age of I 8

One or both of her children abuse drugs or alcohol

One or both of her children commit a felony

One or both of her children commit domestic violence or child abuse

Anything else negative or detrimental that results as a nexus from the claims
presented herein-or the Defendants subsequent actions against the estate

5I5. That the Court must appoint an attorney or solicitor for the minor children or bar all
defendants from employing attorneys in this matter otherwise it will result in a gross
miscarriage of justice and abrcgate the common law and equity here.

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516. The Court is required to appoint an attorney for the minor children pursuant to Rule 17
(c)(2) if it will not allow Karin Wolf to sue on their behalf.
517. As sole Conservatrix-of thel'amily estate, Karin Wolf has a right to sue on behalf of her
children pursuant to FRCP Rule 17 (c)(I)(A, C, and D).
51&. There are two maxims of Law that apply here:
A) Truth is Expressed in the Form of an Affidavit.
B) An Unrebutted Affidavit stands<ts Truth in the Matter.
519. Plaintiff Karin Wolf has provided the Court with sworn affidavits that stand as truth in
Law. The time to rebut them is expired.
520. Defendants STATE and CRANE failed to rebut said affidavits and therefore
acquiesced to the preswnptions and certainties in said affidavits.
521. Said affidavits established a trust and declare Karin Wolf as sole parent and trustee or-o
and G, with sole authority.
522. That at all times mentioned herein, defendants are interfering with Karin Wolf's sole
residential and legal custody of D and G and unlawfully administering her estate.
523. That at all times mentioned herein, defendants are trespassing and continue to trespass
upon Karin Wolf's estate and property.
524. That at all times mentioned herein, defendants are damaging Plaintiff Karin Wolf's
estate and property.
STATE Defendants are not immune
525. Administrative acts are not protected by sovereign or judicial immunity.
526. Defendant judge> named herein do not have immunity for administrative acts.

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527. By way of example, Defendants PETER DOYNE, BONNIE MIZDOL, and DIANA
MOSKAL reassigned the case of Wolf (Crane) v. Crane, Docket# FM-02-439-07 to
DefendanL GERAill C. ESCALA, upon Defendants CRANE and PETER VAN
AULEN, ESQ. bribing them, in order to predetermine the outcome of the case in
CRANE'S favor.
528. This was done immediately after a Final Restraining Order hearing against Defendant
CRANE, where Defendant WILLIAM R. DELORENZO was disturbed upon hearing
evidence showing Defendant CRANE abusing the children.
529. Defendant officials named herein do not have immunity for administrative acts.
530: Defendants STATE OF NEW JERSEY and its employees named herein do not have
immunity.
531. Defendants DCP&P and its employees named herein do not have immunity.

UCCJEA Violations
532. Defendants CRANE and VAN AULEN, Esq. failed to file the mandated UCCJEA
affidavit pursuant to NJ Rule 2A:34-73 and information required pursuant to NJ Rule
5:4-2(a)(2). Defendants DELORENZO, MIZDOL, ESCALA, and MOSKAL ignored
these requirements, which are mandatory to invoking subject matter jurisdiction, and
allowed 3+ years of custody litigation and a custody trial to take place in violation of
the UCCJEA.
533. Said Defendants deliberately ignored that Bergen County was an improper venue
pursuant to NJ Rule

5:2~1(b)(l)

and l.ooiWn v. Marino, 179. N J. Super. 164 (App. Div.

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1981 ). According to the statute, venue, which in this case is actually subject-matter

jurisdiction notwithstanding typical venue rules, was proper in Morris County rather, as
there was no authority to lay it elsewhere; child custody is an in rem jurisdictional issue,
making the entire custody litigation since February 1, 201-1 a nullity, as subject matter
jurisdiction was not present.
534. Plaintiff Karin brought this to the attention of the trial court and the appellate, proYidlng
statutes and case law that back this up, where venue becomes jurisdictional, citing
Carter v. Carter, 278 So.2d 394, 3% (Miss. 1973), National Heritage Realty, Inc. v.
Estate of Boles, 947 So.2d 238 (Miss. 2006), reh. den. February 8, 2007, Pdce.v. Price,
32 So.2d 124 (Miss. 1947).
535. NJ Rule 5:2-1 is exempt from accordance with NJ Rule 4:3-3. Therefore, all-orders as
of Feb. 1, 201 I and those based on it are void ab initio,- yet the State of New Jersey
refuses to recognize this. Judges who proceed without subject matter jurisdiction render
the proceedings coram non judice, and are therefore subject to personal liability to the
Plaintiffs named herein.
536. In addition, when a-judge violates a litigant's constitutional rights, subject matter
jurisdiction is lost.
Defendant STATE OF NEW JERSEY does not have jurisdiction
537. By affidavit, Plaintiff Karin Wolf retroactively revoked all Power of Attorney from the
State of New Jersey. This is the status at present.
538. By affidavit, all orders of the BERGEN COUNTY COURT, Wolf (Crane) v. Crane,
Docket# FM-02-439-07 are void.

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539. That STATE OF NEW JERSEY and THE BERGEN COUNTY COURT does not have
subject matter jurisdiction over the care, custody, and status oLD and G.
540. That STATE OF NEW JERSEY and THE BERGEN COUNTY COURT never had
subject matter jurisdiction over the care, custody-, and status of D and G.
541. That STATE OF NEW JERSEY and THE BERGEN CC'llJNTY COURT does not have
in personam jurisdiction over Karin Wolf.
542. That STATE OF NEW JERSEY and THE BERGEN COUNTY COURT never had in
personam jurisdiction over Karin Wolf.
543. That STATE OF NEW JERSEY and THE BERGEN COUNTY COURT has no
authority to adjudicate matters of live, flesh-and-blood human beings such as myself
and my children. "Inasmuch as every government is an artificial person, an abstraction,
and a creature of the mind only, a government- can interface'-only with other artificial
persons. The imaginary, having neither actuality nor substance, is foreclosed from
creating and attaining parity with the tangible. The legal manifestation of this is that no
government, as well as any law, agency, aspect, court, etc. can concern itself with
anything other than corporate, artificial persons and the contracts between them." S.C.R.
1795, Penhallow v. Doane's Administrators (3 U.S. 54; 1 L.Ed. 57; 3 Dall. 54).
544. THE STATE OF NEW JERSEY and THE BERGEN COUNTY COURT breached a
Trust that was illegally acquired.
545. THE STATE OF NEW JERSEY and THE BERGEN COUNTY COURT are fired.
546, That Defendant CRANE has not proven paternity or parentage and is administering the
estate of Karin Wolf without authority.

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547. That the State of New 1ersey has not proved paternity or parentage of Defendant
CRANE.
548. That the Court must appoint an attorney or solicitor for Plaintiff Karin Wolf or bar all
defendants from employing attorneys in this matter otherwisdt will result in a gross
miscarriage of justice and abrogate the common law-and equity here.
Pleadings and Evidence by Attorneys Are Barred by

Hear~ay

and Estoppel

549. Defendant PETER VAN AULEN, ESQ. unlawfully admitted evidence and testified as
an attorney during the entire proceedings in the case of Wolf ECrane) v. Crane, Docket#
FM-02-439-07. He is not a competent witness. His statements are inadmissible.
550. The Supreme Court of the United States settled this in Trinsey-v. Pagliaro.
551. "An attorney for the plaintiff cannot admit evidence ;nto the court. He is either an
attorney or a witness". Trinsey v. Pagliaro, D.C.Pa. 1964,229 F. Supp. 647.
552. "Statements of counsel in their briefs or argument while enlightening to the Court are
not sufficient for purposes of granting a motion to dismiss or -summary judgment."
Trinsey v Pagliaro, D.C.Pa. 1964,229 F. Supp. 647.

553. In fact, at all times mentioned herein, Defendant CRANE did not present BERGEN
COUNTY COURT with any pleadings sworn under oath by a proper administrator.
554. "Statutes forbidding administering of oath by attorneys in cases in which they may be
engaged applies to affidavits as well." Deyo v. Detroit Creamery Co (Mich 1932) 241
N.W.2d24.
555. No facts were before the BERGEN COUNTY COURT to establish jurisdiction.

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