criminal complaint filed with the bergen county prosecutor's office against the officers of the...

5/27/2018 Criminal Complaint filed with The Bergen County Prosecutor's Office against t...

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IRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter. 2River Edge, New Jersey 07661

Page 2 of28June 28, 2012

which have been committed by the Officers of the Court to deprive me from my civil rights andNOT BECAUSE I was not satisfy with Judge Doyne's Decisions, BUT Mr. Keitel was notinterested in listening to my report or even looking at the related direct physical evidences and hekept saying that the matter was Civil and not Criminal and the direct physical evidences (relatedCourt Documents and Records) were my opinions.'

As much as I was permitted and I could 4, I reported the following intentional violationsof the Laws and the Rules ofNJ Superior Court which have been committed by the Officers ofthe Court in order to aid and abet the Defendants (Elmwood Park BOE et al.) and to deprive me(pro se PlaintifJ) from my civil rights.

Since I was not heard by Mr. Keitel, Assistant Prospector, in the meeting of June 20,2012, I am writing this letter to you, the Bergen County Prosecutor, to report the followingintentional violations of the Laws and the Rules ofNJ Superior Court and criminal conductcommitted by the Officers of the Court which deprived me of my civil rights and caused me tolose my property (my reputation and my job).

PROOFS for all of the followings are the Court Documents and Records (related directphysical evidences) which I had taken with me to submit to Mr. Keitel, Bergen County AssistantProsecutor, in the meeting of 6/2012012 1 cannot annex all of them to this letter because they arevoluminous).

2C:30-6:Crime Of Official Deprivation Of Civil Rights&2C:30-2. Official Misconduct & Obstruction Of Justice& Conspiracy Against Rights

Not to mention when on 10/25/2012, I reported the criminal conduct committed by my employer to the BergenCounty Prosecutor Office (my employer violated NJ Statute OPMA and PERJURED himself to bring false tenurecharges against me which caused me to lose my property my reputation and myjob ]), Mr. Keitel sent me a letterdated 12/2112011 informing me that the Bergen County Prosecutor Office declined to exercise their authority underthe NJ statutes, due to limited prosecutorial resources and informing that I was free to pursue other avenuespotentially available under the statutes, including pursuing the matter in Superior Court.

4 My sister's presence in that meeting could help me.



IRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter, #2River Edge, New Jersey 07661

Page 3 of 28June 28, 2012

A) 2c:28-7. Tampering With Public Records Or Information & 2c:28-6.Tampering With Or Fabricating PhysicalEvidence

1. Many documents have been kept off the record and have not being reflected in AeMS until I(''pro se plaintiff or plaintiff') complained to the clerk's office on or about 4/6/2012 (proofsee the document s of this case in ACMS [DOCKET: BER L -008966 11J)

2. Still many documents (written by: Judge Doyne, the Court, the Defendants, and the Plaintiff[meJ) have been kept off the record, as few example:a) Judge Doyne's letter dated 1117/2012to the parties, stating that:

... Staff has alerted the undersigned that the plaintiff wishes to file a summary judgmentapplication .... A case management conference is scheduled for February 2,2012 at 3:00 p.m .....b) My (Plaintiff's) letter dated 3/22/2012, in objection to judge Doyne's false statement in his

letter dated 3/16/2012.c) Judge Doyne's letter dated 3/27/2012.d) Defendants' opposition dated 3/20/2012 (Filed 3/22/2012) to my motion to amend the

complaint, which was entered into ACMS on 6/6/2012 about 11 days after my (plaintiff's)complaint had been dismissed, as DOC NUM 046. (See the highlighted row of the followingtable)

VENUE BERGEN COURT LAW CVL DOCKET #: L 008966 IICASE TITLE : TOORZANI VS ELMWOOD PARK BD OF ED

DATE FILED DOC DOCUMENT TYPE FILINGff ARGET ATTORNEY MUL DOCNUM PARTY NAME NAME PTY STA

02 24 2012 022 MISCBRIEF ELMWOOD PARK NIRENBERG Y02 27 2012 010 MISCBRIEF TOORZANl PROSE N02 28 1012 011 MOTNMISC TOORZANl PROSE N WD03 02 2012 012 ORDR RECONSIDER TOORZANI PROSE N GR03 02 2012 020 ORD CRG TR ASGN COURTINIT N GR03 13 2012 013 MOTN FL AMD CMP TOORZANl PROSE N GR03 15 2012 019 ORDR orn CSE MG COURTINIT N GR03 22 21)12 6 LTIRMEMRD ELMWOOD PARK NIRENBERG Y03 26 2012 014 MISC BRIEF TOORZANI PROSE N03 27 2012 018 ORDR OTH CSE MG ELMWOOD PARK NIRENBERG Y GRe) Judge Doyne's letter dated 5/16/2012. which that letter was to coerce me (pro se plaintiff) to

participate in deposition (while default had already been entered and motion for default



JRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter. #2River Edge, New Jersey 07661

Page 4 of2SJune 28, 2012

judgment had already been filed) and to respond to the defendants' non-conforming motionto dismiss (which wasfiled by the defendants consequent to entry of default) to aid and abetthe defendants who had no rights for any defense after default had been entered except filinga timely motion to vacate the default, before plaintiff moves and files a motion for defaultjudgment, which defendants did not.

f) Defendants' letter to Judge Doyne dated 5/22/2012, (asking Judge Doyne not to accept themy (plaintiff's) certification and brief which were in objection to defendants' non-conformingfilings which had been filed consequent to entry of default and consequent tofiling my (Plaintiff's) motionfor default judgment).

g) My (Plaintiff's) letter dated 5/23/2012 in response to the above letter.h) Defendants' letter dated 5/23/2012 (stating, defendant withdrew their requestfor oral

argument, which defendants had requested for their non-conforming motions which had beenfiled subsequent to entry of default and subsequent tofiling my (plaintiff's) motionfor defaultjudgment).

i) Two letters to Ms. Stylianou and her responses (regarding Tampering with Documents,Public and Court Records in the Jacket and ACMS).

3. In violation of Rule 1:6-2, per defendants' request Judge Doyne prohibited me (pro se plaintiff)from filing any motion without Judge Doyne's prior permission (proof defendants' letters toJudge Doyne and defendants' oppositions to my (plaintiff's) motions which are the CourtDocuments and they are not my (plaintiff's) opinion as Mr. Keitel, assistant prosecutor wascalling them when he had not even looked at them, EXIllBIT 1)

4. In violation of rule 4:69-4, not only Judge Doyne coerced me (pro se plaintiff) into discoverywithout determining the factual and legal dispute and marking the exhibits, but he was trickingand intimidating me (pro se plaintiff) to coerce me to sign a prepared trial and discoveryschedule form belong to chancery division. And also in Violation of rule 4:69-4, Judge Doyneprohibited me (pro se plaintiff) from filing an application for summary judgment while he wascoercing me (pro se plaintiff) to file unnecessary motions and letters with the Court to prohibitme from representing my case in fair and orderly manner (proof the taped records of two case



IRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter. #2River Edge, New Jersey 07661

Page 50f28June 28,2012

management conferences of2/2/2012 and 3/15/2012 which are public records and are also inthe possession of the court).

5. In violation of rules 4:46 and 4:69-2, Judge Doyne prohibited me (pro se plaintiff) from filing anapplication for summary judgment (proof the Court Documents, as one example defendants'letter dated 2/22/2012, EXHIBIT 2 ) by the time that I (plaintiff) put my request for JudgeDoyne's permission to file an application for summary judgment on my motion to amend thecomplaint dated 3/13/2012 which was opposed by defendants' opposition dated 3/20/2012(EXHIBIT 3). The Court mischaracterized my (plaintiff's) motion to amend the complaint as themotion for summary judgment (EXHIBIT 4) returnable on 4/13/12 (when I had notfiled anyapplication for summary judgment and I had just simply asked for judge Doyne 'spermission tofile an applicationfor summary judgment) to cover up Judge Doyne's violation of Rules 4:46and 4:69-2, when I (plaintiff) questioned this mischaracterization, the Court change the documenttype and then rescheduled it. (See the highlighted rows of the following table)VENUE :STATEWIDE COURT: LAWCVL DOCKET : BERL 008966 11CASE TITLE: TOORZANI VS ELMWOOD PARK BD OFED

PROCEEDING MOTION MOTION SESSION COURT PROCEED JUDGE PROCEEDINGTYPE DOCrrYPE STATUS DATE ROOM TIME ID STATUS BY:VIA:

STATCONF 091312 426 03 00 PEDOI CANCELMOTIONHRG 34MKl 0615 12 426 0900 PEDOI RSCHEDMOTIONHRG 37 MH3 GRANTED 052512 426 0900 PEDOI COMPLETEDMOTIONHRG 34 MKl DENIED 0525 12 426 0900 PEDOI COMPLETEDMOTIONHRG 33 MAl GRANTED 0525 12 426 0900 PEDOI COMPLETEDMOTIONHRG 25 M99 DENlED 05 11 12 426 0900 PEDOI COMPLETEDMOTIONHRG 24 M99 DENlED 05 11 12 426 0900 PEDOI COMPLETEDMOTIONHRG 13MB3 041312 426 0900 PEDOl RSCHEDMOTIONHRG 13 MB3 GRANTED 0330 12 426 0900 PED01 COMPLETEDMOTIONHRG 11M99 WTHDRW MTN 031612 426 0900 PEDOI CANCEL



IRANDOKHT TOORZANTPLAINTIFF, Pro se175 oxford ter. #2River Edge, New Jersey 07661


6. Judge Doyne violated the Rules 4:43 (Default) and 1:5-6 (filing), when judge Doyne acceptedthe non-conforming filings from defendants including a motion to dismiss which had a non-conforming affidavit in violation of rule 4:23-5(a)15 in its support and had been filed consequentto entry of default on 5/9/2012, an answer to verified amended complaint filed on 5/10/2012which was a general denial 6 (consequent to entry of default on 5/9/2012), and a certificationcontains false statements filed on 511112012 (consequent tofiling my (plaintiff's) motion fordefault judgment on 5/10/2012@ 2:38 PM).

Once a default is entered, the defendant has no right to participate in a lawsuit until thedefault has been set aside. The only motion that a defendant can file is a timely motion to berelieved from default before the motion for default judgment be filed. The court has noauthority to consider any other pleading or motion.

7. Judge Doyne violated the Rules 4:43 (Default), 1:6-3(a) (filing motion), and 1:6-3(b) (filing crossmotion) when he relied on the defendants' non-conforming certification filed on 5/1112012(which was filed after default had been entered by the Court Clerk on 5/9/2012 and after I(plaintiff) hadfiled my motionfor default judgment on 5/10/2012) and unlawfully struck(EXHIBIT 5) the default on 5115/2012, in violation of Rule 4:43 and then let the defendantsfile a non-conforming motion (Motion Vacate Default/Extend Time Answer) out of time on5116/2012 (returnable on 5/25/2012) without existence of any Court Order permitting that filing,in violation ofthe Rules of Court and under guise of cross motion to my (plaintiff's) motion fordefault judgment (not to mention that the ACMS indicates that my (plaintiff's) motionfor defaultjudgmentfiled on 5/10/2012 was rescheduledfor the next cycle 6/15/2012 by the Court, which I(plaintiff) did not have any knowledge about it). The proofs are the Court Documents andRecords, and not my (plaintiff's) opinion as Mr. Keitel was calling them in the meeting of6/20/2012 (See the highlighted rows of the following table)

5 The defendants were IN DEFAULT in discovery obligations owed to plaintiff (defendants were in default in therequested admissions dated 2/2/2012 propounded to defendants by Plaintiff).

6 Even Defendants' proposed responsive Answer to the verified amended Complaint was not illustrating to the courtthat the Defendants have a meritorious defense to the Plaintiff's verified amended complaint.



IRANDOKHT TOORZANIPLAfNTIFF, Pro se175 oxford ter. #2River Edge, New Jersey 07661


VENUE : STATEWIDE COURT: LAW CVL DOCKET # : BER L 008966 11CASE TITLE: TOORZANI VS ELMWOOD PARK BD OF EDPROCEEDING MOTION MOTION SESSION COURT PROCEED JUDGE PROCEEDINGTYPE DOCrrYPE STATUS DATE ROOM TIME ID STATUS BY:VIA:STATCONF 091312 426 0300 PEDOl CANCELMOTlONHRG 34MKI 061512 426 0900 PEDOI RSCHEDMOTIONHRG 37 MH3 GRANTED 052512 426 0900 PEDOI COMPLETEDMOTlONHRG 34 MK1 DENIED 052512 426 0900 PEDOI COMPLETEDMOTIONHRG 33 MAl GRANTED 052512 426 0900 PEDOI COMPLETEDMOTIONHRG 25 M99 DENIED 05 11 12 426 0900 PEDOI COMPLETEDMOTIONHRG 24 M99 DENIED 0511 12 426 0900 PEDOl COMPLETEDMOTIONHRG 13MB3 041312 426 0900 PEDOI RSCHEDMOTIONHRG 13MB3 GRANTED 033012 426 0900 PEDOI COMPLETEDMOTIONHRG 11M99WTHDRWMTN 031612 426 0900 PEDOI CANCEL

Although the trial court has broad discretion to set aside the entry of a default or defaultjudgment, but the Court can only utilize that discretion, if the defendant establishes the properground for relief, follows the appropriate procedure, and [des the motion (motion to vacatethe default) within the mandatory time limits, which here in this case defendants did not, as theCourt Documents and Records prove it.

8. Judge Doyne violated the Rules 4:23-5(a)1 and 4:23-5(c), when he accepted the defendants' non-conforming motion to dismiss, filed on 5/912012 consequent to entry of default. 7The motion was non-conforming since:a) It had been filed consequent to entry of default.b) Even regardless of part (a) of this paragraph (~8), defendants' motion to dismiss was not

supported by a conforming affidavit 8 in accordance with Rule 4:23-5(a)1.

7Not to mention that the defendants' motion to dismiss the plaintiff's verified amended complaint was filed after thedate that the answer to verified amended complaint was due which consequently could not toll the time to answerthe verified amended complaint and accordingly defendants were in default and after the entry of default, defendantshad no right to any defense except filing a timely motion to vacate the default before a motion for default judgmentbe filed.This non-conforming affidavit, in violation of rule 4:23-5(a)l, intentionally was not citing that the defendants wereIN DEFAULT in discovery obligations owed to the plaintiff (defendants were in default in the requested admissionby laintiff and was not stating that Plaintiff had already responded to all the propounded interrogatories by thedefendants and she had produced all the documents requested by the defendants. However defendants' attorneys

Continued on the next page



IRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter, #2River Edge, New Jersey 07661


9. Making False Documentation And Record: on 5/25/2012, three orders were filed by the Courtas follows: (See the highlighted row of the following table)DATE FILED DOC DOCUMENT TYPE FILINGfT ARGET ATTORNEY MUL DOC

NUM PARITNAME NAME PIT STA

5 25 2 12 43 ORDR DISM CMPL ELMWOOD PARK NIRENBERG Y GR

5 25 2 12 44 ORD ENT DEF JUD TOORZANI PROSE N DN

5 25 2 12 45 ORD VC DF EX TM ELMWOOD PARK NIRENBERG y GR

but I (pro se plaintiff) was given just two orders DOC NUM 043 (ORDR DISM CMPL) andDOC NUM 045 (ORD VC DF EXTM) which Judge ~oyne's finding and reasoning for grantingthose motions (the defendants' motions) had not been appended to those orders (Judge Doyne,orally had stated his finding and reasoning in the absJnce of parties, even though that I(plaintiff) and defendants had consented to not to have oral argument. I (pro se plaintiff) had topay more than $100 tofind out what Judge Doyne 's fi~ding and reasoning had been).

IMORE IMPORTANTLY I (pro se plaintiff) was told by the Court's staff that NO PhysicalDocument for DOC NUM 044 (ORD ENT DEF JUD) existed, which consequently made me(plaintiff) unable to appeal Judge Doyne's order denying my motion for default judgment sinceJudge Doyne's physical order denying my motion for default judgment, which has been enteredinto ACMS as DOC NUM 044 fORD ENT DEF JUD, DOES NOT EXIST.

10. Making False Documentation And Record: Entering a certification (DOC NUM 027) intoACMS on 5/7/2012 by the Court when NO such Document existed (EXIllBIT 6). After I

were looking for an specific recording (oral statements made to Plaintiffby the witnesses who are available to theDefendants while the essence of what Defendants' attorneys were seeking, had been revealed to them throughinterrogatories, and Verified Amended Complaint, and was/is readily available to them direct from the witnesses forthe asking) from several years tape recording (Defendants' attorneys were lookingfor those oral statements to helpprepare themselves to examine the witnesses who are Defendants' employees and available to them and to makesure that they have overlooked nothing) which was a massive work and an undue burden on Plaintiff to produce itand was also protected by work product.



IRANDOKHT TOORZANTPLAINTIFF, Pro se175 oxford ter. #2River Edge, New Jersey 07661

Page 90f28June 28, 2012

(plaintif}) learned about this matter and I went to the Court to ask for a copy of that certification,was told by the staff ofthe clerk's office that they did not know where that certification waslocated (when ACMS was indicating that the said certification had been filed on 5/2/2012) andthey could not provide me with a copy of that certification and I was told if I wanted to get acopy of that certification I had to go back to the Court after a week. Then, when I asked themhow they could not provide me with a copy of that certification that they claimed had been filedalmost a week before, they gave me a copy of defendants' letter dated 4/27/2012 addressed toJudge Doyne.Later, after several times that I complained to several places including the Bergen CountyProsecutor Office regarding this matter (EXHIBIT 7), on 5/9/2012, Court changed theDocument Type from Certification to LTTR MEMRD (EXHIBIT 8). (See the highlightedrows of thefollowing tables)

VENUE BERGEN COURT : LAW CVL DOCKET #: L 00896611CASE TITLE: TOORZANI VS ELMWOOD PARK BD OF ED

DATE FILED DOC DOCUMENT TYPE FILINGfTARGET ATTORNEY MUL DOCNUM NONCONF PARTY NAME NAME PTY STA04 05 2012 017 ORDR FLAMD CMP TooRZANI PROSE N GR04 16 2012 023 COMP AMENDED TooRZANI PROSE N04 16 2012 024 MOTNMlSC TooRZANI PROSE N DN04 19 2012 025 MOTNMlSC TooRZANI PROSE N DN04 30 2012 026 MlSCBRlEF TooRZANl PROSE N05 02 2012 027 CERTIFICA nON ELMWOOD PARK NIRENBERG Y05 03 201.2 028 MlSCBRlEF ELMWOOD PARK NIRENBERG Y05 04 2012 029 MlSCBRlEF TooRZANI PROSE N05 09 2012 031 REQDEFLT TooRZANI PROSE N05 10 2012 030 ANS JRY DEMAND TOORZANI PROSE N

11

VENUE BERGEN COURT : LAW CVL DOCKET #: L 00896611CASE TITLE: TOORZANl VS ELMWOOD PARK BD OF ED

DATEFILED DOC DOCUMENT TYPE NON FILINGfTARGET ATTORNEY MUL DOCNUM CONF PARTY NAME NAME PTY STA04 05 2012 016 MlSCBRlEF TOORZANI PROSE N04 05 2012 017 ORDR FLAMD CMP TooRZANI PROSE N GR04 16 2012 023 COMPAMENDED TooRZANI PROSE N04 16 2012 024 MOTNMlSC TooRZANI PROSE N DN04 19 2012 025 MOTNMlSC TOORZANI PROSE N DN04 30 2012 026 MISCBRIEF TooRZANI PROSE N05 02 2012 027 LTfRMEMRD ELMWOOD PARK NIRENBERG Y05 03 2012 028 MlSCBRIEF ELMWOOD PARK NIRENBERG Y05 04 2012 029 MISCBRIEF TOORZANI PROSE N05 09 2012 031 REQDEFLT S TOORZANI PROSE N



fRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter. #2River Edge, New Jersey 07661


12. Mischaracterizing The Documents: Court mischaracterized my (plaintiff's) motion to changethe track 9 filed on 2/14/2012 as motion to reconsider and also mischaracterized my proposedorder attached to my motion as order to reconsider 10. Then Judge Doyne created his own orderdated 3/2/12, as order to change the track initiated by court (EXHIBIT 9) as his order andresponse to my motion to change the track assignment, in order to address and grant thedefendants' demands which had been requested by defendants via their opposition to plaintiff'smotion to change the track (Defendants had asked Judge Doyne to prohibit plaintiff from filingany motion without his prior permission, specially motion for summary judgment via theiropposition; EXHIBIT 10 In that created order dated 3/2/12, Judge Doyne stated:

... FURTHER ORDERED that nothing herein shall serve to modify the case management orderheretofore entered and, more particularly but not by way of limitation, the provision that nomotion can be filed absent court permission ...

when even that case management order did not have such a provision that no motion canbe filed absent court permission (EXHIBIT 11) (See the highlighted rows of thefollowing tables).

VENUECASE TITLE

BERGEN COURT LAW CVL DOCKET #: L 00896611TOORZANI VS ELMWOOD PARK BD OF ED

DATE FILED DOC DOCUMENT TYPE I FILING/T ARGET ATTORNEY MUL DOCNUM PARTY NAME NAME PTY STA10 28 2011 001 COMP JRY DEMAND TooRZANI PROSE N12 15 2011 002 SUMMONS 99 MOFFITT NIRENBERG N12 15 2011 003 SUMMONS 99 ELMWOOD PARK NIRENBERG N12 15 2011 004 SUMMONS 99 TOMKO NIRENBERG N01 04 2012 005 ANS JRY DEMAND ELMWOOD PARK NIRENBERG Y01 2012 006 NOTC APPEARANCE ELMWOOD PARK NIRENBERG N01 13 2012 007 NOTC APPEARANCE ELMWOOD PARK NIRENBERG Y02 06 2012 008 MlSCOTHER TOORZANI PROSE N2 14 2 12 9 MOTN RECONSIDER TOORZANI PROSE N GR02 16 2012 021 ORDR OTH CSE MG ELMWOOD PARK NIRENBERG Y GR

9 Originally the track assignment had been entered erroneously and despite the fact that Judge Doyne and thedefendants' attorney had knowledge about it none of them took any action to fix that error. When plaintiff realizeabout that error she filed a motion on 2/14/2012 to change the track.

10 When plaintiff asked clerk's off ice for a copy of this order which had been mischaracterize as order to reconsider(DOC NUM 012) plaintiffwas told that such an order did not EXIST.


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Page 11 ufl8June 28, 2012

DATE FILED DOC DOCUMENT TYPE FILINGfT ARGET ATTORNEY MUL DOCNUM PARTY NAME NAME PTY STA2 24 2 12 22 MISCBRlEF - - ELMWOOD PARK NIRENBERG & Y2 27 21m 1 MISCBRlEF TOORZANI PROSE N2 28 2 12 11 MOlNMISC TOORZANI PROSE N WD3 2 2 12 12 ORDR RECONSIDER TOORZANI PROSE N GR3 2 2 12 2 ORD CHG TR ASGN COURTINIT N GR3 13 2 12 13 MOlN FL AMD CMP TooRZANI PROSE N GR3 15 2 12 19 ORDR OTH CSE MG COURTlNlT N GR3 22 2 12 46 LTTRMEMRD ELMWOOD PARK NIRENBERG & Y3 26 2 12 14 MISCBRlEF TOORZANI PROSE N3 27 2 12 18 ORDR OTH CSE MG ELMWOOD PARK NIRENBERG & Y GR

13. Removing and concealing Documents: Removing and concealing a document from the jacketwhich was indicating that default had been entered on 5/9/12, and was a notice addressed todefendants (Document Return/Nonconforming Document Notification), informing thedefendants' attorney that the defendants' answer was being returned to them and had beenmarked received but not filed as the result that defendants had been in default and defaulthad been entered aft amended complaint on 5/9/12.This notice to the defendants' attorney had also directed the defendants' attorney to forward acopy of that notice to plaintiff but defendants' attorney willfully and intentionally failed tofollow the Court's direction by not forwarding the copy ofthat notice to plaintiff (EXHIBIT 12).The defendants' attorney did not forwarded a copy of that notice (DocumentReturn/Nonconforming Document Notification) to me (plaintiff) in order to conceal thatinformation from pro se plaintiff, and fraudulently claim that the defendants had not receivedany notice regarding the entry of default and claim that default had not been entered on 5/912012to fraudulently hinder me (plaintifJ) from getting default judgment. (Once I was making copy ofsome documents from the jacket, I saw the said notice in the jacket but later after afew days Irealized that the said notice had been removed from the jacket. I asked for that missing noticebut nobody was responsive and I was asked if I had made a copy of that notice? [at the time Iwas not sure if I had a copy of that noticeJ and when I inform Ms. Stylianou, civil case manager,regarding this matter, she responded that she only was able to account for each document inACMS, while that notice had not been reflected in ACMS).



IRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter. 2River Edge, New Jersey 07661

Page1l otl8June 28, 2012

B) 2c:28-1.Perjury And Subornation Of Perjury &2c:28-2.False Swearing

14. On 5/16/2012, after default had already been entered on 5/9/2012 and after plaintiff's motion fordefault judgment had already been filed on 5/10/20 12, defendants filed a non-conforming motion( motion to Vacate Default/Extend Time Answer ) 11 out of time under guise ofa cross motion12 to plaintiff's motion for default judgment.The defendants' said motion ( Vacate Default/Extend Time Answer , DOC NUM 037) had beensupported by a certification contains false statements of fact. In that certification defendants'attorney knowingly and intentionally had made several false statements of fact and Rules, whileJudge Doyne had been aware of those falsifications of fact and Rules.In that certification defendants' attorney (Sandra Varano, esq.J certified that:

I hereby certify that the within statements made by me are true. 1am aware that if any of theforegoing statements made by me are willfully false, 1am subject to punishment.

and while defendants' attorney (Sandra Varano, esq.) has been aware that a certificate shall setforth only facts to which the person, who has made it, is competent to testify, defendants'attorney (Sandra Varano, esq.) certified in that certification on:i page 1, '2 & page 5, , 23 that,

2. This certification is offered in opposition to the plaintiffs motion for default judgment and insupport of defendants' cross-motion to vacate any default entered.23. For the foregoing reasons, it is respectfully requested that the plaintiff's motion for default

and/or default judgment be denied and that any default previously entered be vacated.A proposed form of order is annexed hereto.

11 Non-confirming, since 1. Plaintiff's motion for default judgment had already been filed, and default had alreadybeen converted to motion for default judgment 2.The Court had scheduled this motion Vacate DefaultlExtendTime Answer for 5/25/2012, in violation of Rule 1:6-3(a), which says: ... a notice of motion shall be filed andserved not later than 16 days before the specified return date unless otherwise provided by court order. .. when NOCourt order had provided permission to the defendants to file this motion Vacate DefaultlExtend Time Answerout of time

12 Even as cross motion it was non-conforming, since the subject matter of defendants' cross motion was different thanthe subject matter of plaintiff's motion which was a motion for default judgment.





'2 and ~ 23 (highlighted part) of the defendants' attorney's certification are false statementsof fact which denotes conduct which is fraudulent and has a purpose to deceive byintentionally making the impression that plaintiff had filed a motion for default and defaultjudgment simultaneously. When in fact, default had been entered on 5/9/2012 (anddefendants were aware of that; EXIllBIT 12) and plaintiff had moved to convert the defaultto default judgment on 5110/2012 by filing a motion only and only for default judgment (Seeplaintiff's proposed order which had been attached to her motion for default judgment;EXHIBIT 13) and thereafter defendants could not legally file any application under guise ofcross motion to vacate the default consequent to filing plaintiff's motion for defaultjudgment.

RULE; 1:6-3(b),Cross-Motions. A cross-motion may be filed and served by the respondingparty together with that party's opposition to the motion and noticed for the same return date onlyif it relates to the subject matter of the original motion, except in Family Part motions broughtunder Part V of these Rules where a notice of cross-motion may seek relief unrelated to thatsought in the original motion ....

ii page 1,'4 that,4. The documents annexed as Exhibit A are the only documents I have received from plaintiff withrespect to the entry of default. Thus, I have never been served with the Entry of Default (page 3 of 3of Exhibit A) with a clerk's signature indicating that default had in fact been entered.

, 4 (highlighted part) of the defendants' attorney's certification is false statement of facts,since defendants had been served with the notice (Document Return/NonconformingDocument Notification) by the clerk's office, informing the defendants' attorney that thedefendants' answer was being returned to them and had been marked received but notfiled as the result that defendants had been in default and default had been entered a/tamended complaint on 5/9112. This notice to the defendants' attorney had also directed her toforward a copy of that notice to plaintiff but defendants' attorney willfully and intentionallyfailed to follow the Court's direction by not forwarding the copy of that notice to plaintiff(EXHIBIT 12). The defendants' attorney did not forwarded a copy of that notice (DocumentReturn/Nonconforming Document Notification) to me (plaintiff) in order to conceal thatinformation from me (pro se plaintiff), and fraudulently claim that the defendants had notreceived any notice regarding the entry of default and claim that default had not been enteredon 5/9/2012, to fraudulently hinder me (plaintiff) from getting default judgment.



JRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter, 2River Edge, New Jersey 07661

Page 14 of2NJune 28, 2012

iii page 2, ,- 5 &page 5, ~ 22 that,S.NQ such documentation has been filed with the plaintiffs motion for default judgment. In fact,it appears that the relief sought by the motion is for both default and default judgment. R 4:43-2specifically provides that default and default judgment cannot be sought simultaneously.22. That plaintiff should seek default judgment the day after she requested entry of default and

without ever having provided proof that default was entered is further evidence of plaintiffsrepeated attempts to avoid actually litigating the merits of her claim.

~ 5 (highlighted part) of the defendants' attorney's certification is false statement of factwhich denotes conduct which is fraudulent and has a purpose to deceive. The defendants'attorney' has intentionally made this false statement (highlighted part) to justify their non-conforming motion (Motion Vacate Default/Extend Time Answer) which was filed out oftime, under guise of cross motion in violation of Rules 4:43 (Default), 1:6-3(a) (filingmotion), and 1:6-3(b) (filing cross motion).The defendants' attorney had been served with the notice (Document Return/NonconformingDocument Notification) by the clerk's office, informing the defendants' attorney that thedefendants' answer was being returned to them and had been marked received but notfiled as the result that defendants had been in default and default had been entered aftamended complaint on 5/9/12. (EXHIBIT 12)This notice to the defendants' attorney had also directed the defendants' attorney to forward acopy of that notice to the plaintiff but defendants' attorney willfully and intentionally failedto follow the Court's direction by not forwarding the copy of that notice to plaintiff(EXHIBIT 12). The defendants' attorney did not forwarded a copy of that notice (DocumentReturn/Nonconforming Document Notification) to me (plaintiff) in order to conceal thatinformation from pro se plaintiff, and fraudulently claim that the defendants had not receivedany notice regarding the entry of default and claim that default had not been entered on5/9/2012, to fraudulently hinder me (plaintifJ) from getting default judgment and tointentionally and fraudulently make this impression and belief that (plaintiff) had filed amotion for default and default judgment simultaneously. When in fact, default had been





entered on 5/9/2012 (and defendants were aware of that; EXHIBIT 12) and I (plaintiff) hadmoved B to convert the default to default j:ndgment on 51] 0/2012, by filing a illotion only andonly for default judgment (See plaintiff's proposed order which had been attached to hermotfonfor defarultjttdgmQl'7 ; -VXHiBIT 13) and thereafter defendants could not legally fileany application under guise of cross motion to vacate the default consequent to filingplaintiff's motion for default judgment. I~22 of the defendants' attorney's certification is again false statements of fact which denotesconduct which is fraudulent and has a purpose to deceive by intentionally making theimpression that I (plaintiff) have been avoiding to litigate the merits of my claims when theCourt Documents and Records prove otherwise (EXHIBIT 2 3) in facts defendants havebeen using their influence on Judge Doyne to coerce him to violate the Rules of Court inorder to aid and abet the defendants since defendants have been the ones who have not hadany meritorious defense and they had to violate the Laws and the Rules ofNJ superior Courtto win this case.

If defendants were not sure that plaintiff's claims had merits, defendants and JudgeDoyne would never violate the Rules ofNJ Superior Court to prohibit plaintiff from filing anapplication for summary judgment or would never try to unlawfully dismiss the Plaintiff sverified amended complaint by using a non-conforming motion (which had been alsosupported by a non-conforming certification) which had been filed consequent to entry ofdefault. to dismiss the plaintiff s verified amended complaint, when defendants had alreadyfailed to answer the plaintiff's verified amended complaint fu+ter 57 days from the service ofa..'11endedpleading; or after 32 days that the motion to amend the complaint was granted on4/5/2012; or after 22 days that the same copy of the verified amended complaint was fliedallover again per Judge Doyne's order on 4/17/2012.

11 When T(plaintiff) called the Court to see why I had not received the page 3 of 3 of my request for entry of defaultwith clerk's signature, I was told that the default had been entered but I had not received the copy of entry of defaultsince I had not provided them with an extra copy and a return envelope.



JRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter. #2River Edge, New Jersey 07661

Page 16of28June 28, 2012

iv. page 2, 6 &page 4,'16 that,6. Annexed hereto as Exhibit B is a copy of the defendants' answer to the plaintiffs amendedcomplaint that was stamped FILED by the Bergen County Deputy Clerk on May 10,2012.16. To the extent a default has already been entered, it is respectfully submitted that the

defendants' cross motion to vacate same be granted and that defendants be permitted to file ananswer to the amended complaint, although as set forth in Exhibit B, that answer has in factalready been filed.

~6 and ~ 16 (highlighted part) of the defendants' attorney's certification are false statementof fact which denotes conduct which is fraudulent and has a purpose to deceive. Thedefendants' attorney' has willfully and intentionally made these false statements (highlightedpart) when there is the direct physical evidence which proves that the defendants' attorneyhad been served with the Court notice (Document Return/Nonconforming DocumentNotification; EXHIBIT 12 by the clerk's office, informing the defendants' attorney that thedefendants' answer had not been filed, the defendants' answer was being returned to themand the defendants' answer had been marked received but not filed as the result thatdefendants had been in default and default had been entered aft amended complaint on5/9/12. (EXHIBIT 12This notice to the defendants' attorney had also directed the defendants' attorney to forward acopy of that notice (Document Return/Nonconforming Document Notification) to the plaintiffbut defendants' attorney willfully and intentionally failed to follow the Court's direction bynot forwarding the copy ofthat notice to' plaintiff (EXHIBIT 12 The defendants' attorneydid not forwarded a copy of that notice (Document Return/Nonconforming DocumentNotification) to me (plaintiff) in order to conceal that information from pro se plaintiff, tofraudulently claim that the defendants had not received any notice regarding the entry ofdefault and default had not been entered OIn 5,j~)i/2m and the defendants' answer had notbeen returned to defendants marked received but not filed as the result that thedefendants had been in default to fraudulently hinder me (plaintifJ) from getting defaultjudgment and to intentionally and fraudulently make this impression and belief that I(Plaintiff) had filed a motion for default and default Judgment simultaneously. And also tojustify defendants' non-conforming motion (Motion Vacate Default/Extend Time Answer)which was filed out oftime, under guise of cross motion to plaintiff's motion for default





judgment in violation of Rules 4:43 (Default), 1:6-3(a) (filing motion), and 1:6-3(b) (filingcross motion).

Defendants' answer was filed after Judge Doyne violated Rule 4:43-3 on 5/15/2012 andstruck the default (which had been entered on 5/9/2012) based on defendants non-conforming certification which was filed on 5/11/2012 subsequent to filing plaintiff'sapplication for default judgment. When Judge Doyne had actual knowledge that inaccordance with the Rules ofNJ Superior Court, when the Court Clerk entered the default(which in this case Default had been entered on 5/9/2012), in order to vacate the entry ofdefault defendants had to file a timely motion (and not a non-conforming out of time motionsubsequent to filling plaintiff's motion for default judgment under guise of cross motion) andNOT an opposition or certification to set aside the default R. 4:43-3).

v. page 2 6 page 2 8 that,6. ..... In the certification included in that answer, I specifically indicate that the answer was filedand served pursuant to R. 4:6-1 (d) s ince no service of the amended complaint was effectuated inaccordance with the requirements oiR. 1:5-2.8. Specifically, it was noted that the plaintiff never served the amended complaint in accordancewith the clear requirements ofR. 1:5-2 which addresses the manner in which service is to made ofpleadings subsequent to the original complaint. Specifically, that rule provides in pertinent part:Service upon an attorney of papers referred to in R. 1:5-1 shall be made by mailing a copy to theattorney at his or her office by ordinary mail, by handing it to the attorney, or by leaving it at theoffice with a person in the attorney's employ, or, ifthe office is closed or the attorney has nooffice, in the same manner as service is made upon a party. [Emphasis added].

Defendants' attorney willfully and intentionally made these falsifications of fact here -r 6and -r8 and in her certification of service included in the defendants' answer to the plaintiff'sverified amended complaint, when Rilles 1:5.2 and 1:5.3 say:

Rule 1:5-2Manner of Service: ... The specific facts underlying the diligent effort required bythis rule shall be recited in the proof of service required by R. 1:5-3. If, however, proof ofdiligent inquiry as to a party's whereabouts has already been filed within six months prior toservice under this rule, a new diligent inquiry need not be made provided the proof of servicerequired by R. 1:5-3 asserts that the party making service has no knowledge of any facts differentfrom those recited in the prior proof of diligent inquiry.Rule 1:5r3 Proof of Service: Proof of service of every paper referred to in R_ 1:5-1 may he made(l) by an acknowledgment of service, signed by the attorney for a party or signed andacknowledged by the party, or (2) by an affidavit of the person making service, or (3) by acertification of service appended to the paper to be tiled and signed by the attorney for theparty making service. . ..




Page 18 of28June 28,2012

And Rule 4:4-says:Rule 4:4-6 (General Appearance; Acknowledgment of Service): A general appearance or anacceptance of the service of a summons, signed by the defendant's attorney or signed andacknowledged by the defendant (other than an infant or mentally incapacitated person), shallhave the same effect as if the defendant had been properly served.

and in accordance with the above said Rules, the defendants had been properly served withthe Plaintiff's Verified Amended Complaint via E-mail [email protected] proof of the proper service in accordance with the above said Rules is the plaintiff'scertification of service of 3/13/2012, as well as other plaintiff's certifications of service of thePlaintiff's motions which show that those motions had been served to the defendants'attorney via the same E-mail address during last several months (since 1012812011 thatplaintiff's complaint had been filed in Bergen County Superior Court) which had never beenobjected by the defendants (Defendants never requested any of the plaintiff'sfilings on thepaper) 4Therefore the manner of service of plaintiff's motions and filings which had never beenobjected by the defendants' attorney, had been considered proper by the defendants' attorney(those motions served via the said above E-mail address, had always been opposed andaccordingly acknowledged by the defendants' attorney) and the Court since plaintiff hadnever been served with any notice from the court that the manner of service of plaintiff'sfillings had been non-conforming in accordance with the Rules of Court.

14 As Defendants and Judge Doyne are aware, this complaint was filed in the Bergen County Superior Court on10/28/2011, and since then all the documents (which plaintiff has been filing with the Court) have being sent toDefendants via E-MAIL address [email protected] (except the original complaint, Summons, CIS, andTAN which were served to Defendants via BOTH E-mail and Bergen County Sheriff's Office) and DefendantsNEVER objected to receiving the documents (which Plaintiff have been filing with the Court) via E-MAIL. AllPlaintiff's certifications of service for Plaintiff's motions prove that those motions have been served to Defendantsvia E-mail address [email protected] and all the Defendants' responses (oppositions) to Plaintiff'smotions are the proofs of Defendants' acknowledgment of receiving those documents which have being filed withthe Court, via Email address [email protected] .The above records have been available to Judge Doyne to be examined by him all the time (anytime that (plaintiff)have been in the Court and askedfor the Jacket of this complaint, I have been told that Judge Doyne had the Jacketand they had to contact Judge Doyne for his permission to bring the Jaclwt down to the Clerk office).



illANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter, #2River Edge, New Jersey 07661

Page 19of28June 28, 2012

vi. page 2, , 7 that,

7. Annexed hereto as Exhibit C is a certification I submitted to the Court by letter dated May 10,2012, before receiving the plaintiffs motion for default judgment, explaining why the plaintiffwas not entitled to default in this matter.

~ 7 of the defendants' attorney's certification is another false statement of fact since in thisparagraph, the defendants' attorney stated that the defendant's certification is dated5/10/2012 but she has concealed the fact and the information that this certification was filedwith the Court on 5/1112012 (EXHIBIT 14), after defendants had received the copy ofplaintiff's motion for default judgment, which had been filed with the court on 5/1012012 at2:38PM. (EXHIBIT 15).Additionally, in contrast to what defendants' attorney has claimed in ~ 7, the records provethat plaintiff had served the defendants' attorney with the copy of plaintiff's motion fordefault judgment via email on 5/10/2012 at 4:36 PM (EXHIBIT 16) while the defendants'attorney sent Plaintiff the copy of defendants' certification via email on 5/10/2012 at 5:28PM (EXHIBIT 17), after defendants' attorney had received the copy of plaintiff's motionfor default judgment.

vii. page 2, , 9 that,9. The only manner in which the plaintiff sought to serve the amended complaint upon my officewas by email dated April 17, 2012, at 5:54 p.m. (See copy of email annexed as Exhibit D).

~ 9 of the defendants' attorney's certification is false statement of facts since in accordancewith Rule 4:4-6 (General Appearance; Acknowledgment of Service); Rule 1:5.2 (Manner ofService); and Rule 1:5.3 (Proof of Service) the copy ofthe verified amended complaint wasproperly served and also received by the defendants (it was served to the defendants properlyvia email address, [email protected] on 3/13/2012 along with the motion to amendthe complaint. as the plaintiff's certification of service of that motion dated 3/13/2012 aswell as the other Plaintiff's certifications of service of the Plaintiff's motions which had beenserved via the same email address to the defendants during last several months show. Allthose motions had been opposed and accordingly acknowledged by the defendants' attorneysduring last several months) and filed with the Court along with the motion to amend thecomplaint on 3/13/2012 for the first time, even defendants' attorney acknowledged the



mANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter, #2River Edge, New Jersey 07661


receipt of the copy of the verified amended complaint in the open Court during the casemanagement conference of 3115/2012 AS SUCH, the defendants had been in possession ofthe plaintiffs Verified Amended Complaint for exactly 57 days by 5/9/2012 that default wasrequested by plaintiff and was entered by the Court.And again defendants' attorney was served with the same copy ofthe verified amendedcomplaint on 4/17/2012 for the 2nd time via the same E-mail address (since Judge Doyneordered the Plainti{[to file the same Verified Amended Complaint all over again).

viii. page 3, , 11 that,11. Significantly, in the affidavit she submitted in support of the request for entry of default, theplaintiff never indicates the method by which the amended complaint was allegedly served asrequired by R. 4:43-1. Thus, if default was in fact entered, it should not have been as the plaintifffailed to comply with the requirements of the court rule in this regard.

~ 11 of the defendants' attorney's certification denotes conduct which is fraudulent and has apurpose to deceive, since plaintiff stated in her affidavit dated 5/9/2012, that:

A copy of the Verified Amended Complaint was served upon the Defendants' Attorney twice,once on 3/13/2012 along with the certification of service and the notice of motion to amend thecomplaint and for the second time on 4/17/2012 (Defendants' attorney acknowledged thereceipt of the Verified Amended Complaint in the case management conference of 3/15/20ill

In addition to that fact that I (Plaintiff) had stated in my affidavit in support of my request forentry of default that Defendants' attorney acknowledged the receipt of the VerifiedAmended Complaint in the case management conference of 3115/20 12 , Clerk's Office hadbeen well aware of all the plaintiff's certifications of service in which, plaintiff had beencertifying that the defendants had being served with the copies of the motions and pleadingsvia defendants' attorney's E-mail address [email protected] during last severalmonths.Court Clerk entered the default on 5/9/2012 with the awareness ofthe fact that all theplaintiff's pleadings had being served to the defendants via [email protected] incomplying with the Rule 1:5-2. (Manner of Service), Rule 1:5-3. (Proof of Service), and Rule4:4-6. (General Appearance; Acknowledgment of Service).

IX. pa2e 3, , 13 that,





13. It was not until AprilS, 2012, that an order was entered permitting the plaintiff to file theamended complaint. Thus, any claim by the plaintiff that the amended complaint was served onMarch 13,2012, or that I acknowledged receipt ofthe amended complaint at a case managementconference held on March 15,2012, is irrelevant. This was with respect to the motion seekingleave to file the amended complaint and predates by approximately a month the actual filing ofthat pleading.

~ 13 of the defendants' attorney's certification is false statement of fact since a copy of theverified amended complaint was received by the defendants (it was served to them via [email protected] on 3/13/2012 along with the motion to amend the complaint) andfiled with the Court along with the motion to amend the complaint on 3/13/2012 for the firsttime, and defendants' attorney acknowledged the receipt of the copy of the verifiedamended complaint in the Open Court during the case management conference of3/15/2012. AS SUCH, the defendants had been in possession of the plaintiff's VerifiedAmended Complaint for exactly 57 days by 5/9/2012 that default was requested by plaintiffand was entered by the Court.

x. page 3,'14 that,14: Notwithstanding the Court's repeated admonition that the parties are not to file motionswithout the prior permission of the Court, it appears that the plaintiff has filed the within motionfor default judgment without such prior consent. At the very least, there is no indication in themoving papers that such permission was in fact sought and obtained.

Defendants' attorney knowingly and intentionally made the above false statement tofraudulently misrepresent the facts and affirmed them by baseless claims in her certification.Defendants' attorney has been filing defendants' motions without seeking Judge Doyne'sprior permission. These defendants' motions are the non-conforming motion to dismiss theplaintiff's Verified Amended Complaint and the non-conforming and out of time motion toVacate DefaultlExtend Time Answer which was filed under guise of cross-motion toplaintiff's motion for default judgment.

In contrast to the defendants attorneys' above statement (~ 14) and as the Court Recordsshow, Judge Doyne under influence of defendants attorneys) only prohibited plaintiff fromfiling any motion without his prior permission and from filing an application for summaryjudgment in violation of the Rules of the Court to hinder me (pro se plaintiff) fromrepresenting my case in fair and orderly manner to aid and abet the defendants.



~OKHTTOORZANIPLAINTIFF, Pro se175 oxford ter. #2River Edge, New Jersey 07661


Xl. page 4, 1[ 19 that,19. This matter has not been delayed nor has plaintiff been prejudiced by the filing of thedefendants' answer to the amended complaint on May 10, 2012 .

~19 of the defendants' attorney's certification is false statements of fact, since HOWplaintiff has not been prejudice when all the Rules of Superior Court mentioned in this letterhave been violated by the Officers of the Court to aid and abet the defendants.HOW the matter has not been delayed and plaintiff has not been prejudiced when defendantsfailed to answer the plaintiff's Verified Amended Complaint (after 57 days from the serviceof amended pleading; or after 32 days that the motion to amend the complaint was grantedon 4/5/2012 ; or after 22 days that the same copy of the verified amended complaint was filedall over again per Judge Doyne s order on 4/17/2012) and instead filed a Non-Conformingmotion, to dismiss the plaintiffs verified amended complaint subsequent to entry of defaulton 5/9/2012.HOW plaintiff has not been prejudice when Judge Doyne violated Rule 4:43 (Default); Rule1:6-3(a) (filing motion); and Rule 1:6-3(b) (filing cross motion) and relied on the defendants'non-conforming certification filed on 5/1112012 (which was filed after default had beenentered by the Court Clerk on 5/9/2012 and after I (plaintiff) had filed my motion for defaultjudgment on 5/10/2012) and unlawfully struck the default on 5115/2012, in violation of Rule4:43 and then let the defendants file their answer on 5115/2012 (and not on 5/10/2012,defendants' attorney has falsely claimed that answer was filed on 5/10/2012 to conceal thefact that the Court had served the defendants with a notice that the Court had returned thedefendants' answer and marked it received but not filed due to the entry of default) anda non-conforming motion (Motion Vacate Default/Extend Time Answer, which was filed outof time, WITHOUT existence of any Court's Order permitting that out of time motion) on5116/2012 (returnable on 5/25/2012) under guise of cross motion to my (plaintiffs) motionfor default judgment (when the subject matter of defendants' cross motion was different thanthe subject matter of the plaintiff's motionfor default judgment), and more.

xii. page 4, ~ 20 that,20. I was admittedly surprised to learn that the plaintiff had sought default after 20days as I hadbeen under the erroneous belief that the answer is due 30 days after proper service.



TRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter. 2River Edge, New Jersey 07661


As the Court is no doubt aware, parties represented by counsel will as a matter of professionalcourtesy and good faith usually notify opposing counsel that he/she intends to file a defaultwithin a specified period so as to avoid excessive motion practice.

~ 20 (highlighted part) of the defendants' attorney's certification is false statement of fact sinceHOW an attorney who has been litigating in the Court for years does not know about therequired time limit to answer to an amended complaint unless she knowingly and intentionallyclaims that she is incompetent to use it as an excuse for not responding to plaintiffs VerifiedAmended Complaint timely.

15. Additionally defendants' attorney in her Certification ( in support of defendants' motion todismiss[DOC NUM 033J the plaintiff's verified amended complaint) which was filed on5/9/2012 consequent to entry of default, certified that:

I hereby certify the within statements made by me are true. I am aware that of any of the foregoingstatements made by me are willfully fasle I am subject to punishment.

and while defendants' attorney (Sandra Varano, esq.) has been aware that a certificate shall setforth only facts to which the person, who has made it, is competent to testify, defendants'attorney (Sandra Varano, esq.) certified in that certification on:i. page 3 th t

3. the motion is being filed pursuant to permission granted by the Honorable Peter E. Doyne.

~3 of the defendants' attorney's certification is false statement of fact since on 4/27/2012,defendants' attorney Sandra Varano esq. sent a letter to Judge Doyne, stating:

... On behalf of the defendants, I am respectfully requesting the Court's assistance in this regard.It is submitted that the plaintiff is required to provide copies of these recordings or be barred fromrelying upon them for any purpose in this litigation. Should the Court require a formal motion onthis issue, I will proceed to do so upon being so advised.

As the Court Records show, Judge Doyne NEVER issued any letter or order in regard to theabove defendants' attorney's letter and additionally there is NO record of Judge Doyne'spermission to defendants, permitting the defendants to file a motion to dismiss the plaintiff'sverified amended complaint as defendants' attorney has falsely claimed in ~3 of hercertification, unless, this permission which has been claimed by the defendants' attorney, hasbeen granted to defendants via an Ex Parte communication between the defendants and JudgeDoyne.



TRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter. 2River Edge, New Jersey 07661


ii page 2, , 8 that,8. Included among the bases for plaintiff's objection to this request is that the information soughtis subject to protection as trial preparation material and protected by privilege, includingattorney work product and attorney's strategy, legal theories and legal reasoning. The Plaintiff,however, is appearing Pro se.

Defendants' attorney knowingly and intentionally make the above false statement in,8 ofher certification in order to fraudulently take advantage of pro se plaintiff's lack oflegalknowledge about Law when Sandra Varano, Esq, is an attorney and has actual knowledgethat a pro se litigant has the right to claim work product privilege as well.

111. page 2, 9 that,9. Moreover, it submitted that plaintiff 's surreptitious recordings of conversations she allegedlyhad with the defendants is not protected by any such privilege

Defendants' attorney knowingly and intentionally made the above false statement in, 9 ofher certification to fraudulently misrepresent the facts and affirmed them by baseless claims.These several years tape recording had not been done secretly (during last several years innumerous occasions defendants had been informed by me (pro se plaintiff) that I (Plaintiff)had been recording the defendants (EXHIBIT 18) to protect my reputation, since constantlyI had beingfalsely accused of being dishonest, deceitful, liar, and etc by the defendants [myemployer 1who are corrupt, fraud, and perjurer [proofs along with a complaint weresubmitted andfiledwith the Office of Attorney General on 1/19/2012 and while thiscomplaint is still pending in the Office of Attorney General, no investigator has yet beenassigned to this complaint to investigate it).

iv. page 3 11& page 3,'13 that,11. Our rules of discovery are designed to eliminate, as far as possible, concealment andsurprise at trial so that cases are decided upon their merits rather than the skill and maneuveringof counsel. ...13. The plaintiff has offered no legitimate; legally cognizable basis for her refusal to respond tothe defendants' notice to produce. As such, it is respectfully submitted that the Court enter an orderdismissing her complaint and awarding counsel fees and costs to the defendants for having had tofile this motion, consistent with R. 4:23-1 (c).




Page2S of28June 28, 2012

Defendants' attorney knowingly and intentionally made the above false statements in '11 and~ 13 of her certification to fraudulently misrepresent the facts and affirmed them by baselessclaims,

This non-conforming certification of the defendants' motion to dismiss (motion todismiss the plaintiff's verified amended complaint) which intentionally was NOT citing thatthe defendants were IN DEFAULT in discovery bligations owed to pro se plaintiff(defendants were in default in the requested admission by me [pro se PlaintifJJ) in violationof Rule 4:23-5(a)1, also was not stating that I (P aintiff) had responded to all the propoundedinterrogatories by the defendants and I (plainti had produced all the documents requestedby defendants, BUT defendants' attorneys were ooking for a specific recording (oralstatements made to me (pro se plaintiff) by the witnesses who are available to the defendants

had been revealed to them

them direct rom the witnesses or the askin w ich could not be called in an wa a

(defendants' attorneys were lookingfor those or I statements to help prepare themselves toexamine the witnesses who are defendants' emp yees and available to them and to makesure that they have overlooked nothing) which as a massive work and an undue burden onPlaintiff to produce it and was also protected by ork product,

m

andmisa

As the last effort to aid and abet the defend ts to get the fmal judgment in thedefendants' favor, Judge Doyne in his oral finding and reasoning (which was tape- recorded inthe absence qfboth parties and was not appended to his orders; both parties had waived oralargument) in regard to the defendants' non-conforming motion to dismiss, made false statementsoffact and stated that the plaintif:fs request for default was filed consequent to the defendants'




Page 26 of28June 28, 20U

motion to dismiss WHEN the Court Records and ACMS (document list) clearly prove otherwise(EXIllBIT 19). (See highlighted rows of the following table)DATE FILED DOC DOCUMENT TYPE FILINGrrARGET ATTORNEY MUL DOC

NUM PARTY NAME NAME PTY STA4 16 2 12 24 MOTNMISC TOORZANI PROSE N DN4 19 2 12 25 MOTNMISC TOORZANI PROSE N DN4 3 2 12 26 MISCBRlEF TOORZANI PROSE N5 2 2 12 27 LTTRMEMRD ELMWOOD PARK NIRENBERG Y5 3 2 12 28 MISCBRlEF ELMWOOD PARK NIRENBERG Y5 4 2 12 29 MISC BRlEF TOORZANI PROSE NOS 9 2 12 31 REQDEFLT TOORZANI PROSE NOS 9 2 12 33 MOTN DISM COMPL ELMWOOD PARK NIRENBERG y GR5 1 2 12 34 MOT ENT DEF JUD TOORZANI PROSE N DN5 1 2 12 35 ANSWER ELMWOOD PARK NIRENBERG Y5 21 2 12 38 CERTIFICTN TOORZANI PROSE N

Not to mention that On 6118/2012, after I listened to the taped record of Judge Doyne'sfindings and reasoning (in regard to graring the defendants' non-conforming and lor out of timemotions) which I had paid for and obtain; d from the Court, I went to the Court (finance office,clerk office, and Judge Doyne 's chamber and I provided them (the staff) with the followinginformation

Date filed: 5/9112Payment #: 12227CA ~ CC MO CGAmount $30Payer: NinenbergBatch/ref case # 131

to get the exact time of filing of the defendants' motion to dismiss on 5/9/2012.I checked the copy of defendants' motion to dismiss which had been filed with the Court but thatcopy did not have any indication of the time of filing (No stamp with the exact time or No

15 Additionally Judge Doyne in his oral finding and reasoning did not mention anything about my plaintiffs)affidavits and certification and even about my legal contentions which were based on the Rules of Court to justifygranting the defendants' non-conforming and/or out of time motions.



TRANDOKHT TOORZANIPLAINTIFF, Pro se175 oxford ter, #2River Edge, New Jersey 07661

Page 27 of28.June 28, 2012

attached receipt) and I also talked to Court Staff and Mr. Dimakus' , Judge Doyne's Law Clerk,but no one was able to determine the time that defendants' motion to dismiss was filed on5/9/2012, when judge Doyne has claimed on his tape- recorded oral finding and reasoning thatthe defendants' motion to dismiss plaintiff's complaint had been filed before the plaintiffsrequest for entry of default on 5/9/2012.17

I (as a member of public and this society) am just wondering, how many knowing andintentional violation of the Rules ofNJ Superior Court and NJ Statutes (Title 2C) an Officer ofthe Court should have had to be held accountable and be sanctioned with criminal penaltiesand/or rehabilitation efforts for his violation of Laws and his criminal conducts.

2C:30-6. Crime of official deprivation of civil rights: a. A public servant acting or purporting toact in an official capacity commits the crime of official deprivation of civil rights if, knowing thathis conduct is unlawful, and acting with the purpose to intimidate or discriminate against anindividual or group of individuals because of race, color, religion, gender, handicap, sexualorientation or ethnicity, the public servant: (1) ... or (2) denies or impedes another in the lawfulexercise or enjoyment of any right, privilege, power or immunity. ..... e. For purposes ofthissection, an act is unlawful if it violates the Constitution of the United States or the Constitution ofthis State, or if it constitutes a criminal offense under the laws of this State.2C:30-7. Crime of pattern of official misconduct: a. A person commits the crime of pattern of

official misconduct if he commits two or more acts that violate the provisions ofN.J.S.2C:30-2 orsection 2 ofP.L.2003, c.31 (C.2C:30-6). It shall not be a defense that the violations were not partof a common plan or scheme, or did not have similar methods of commission. b. Pattern ofofficial misconduct is a crime ofthe second degree if one of the acts committed by the defendantis a first or second degree crime; otherwise, it is a crime of the third degree, provided, however,that the presumption of nonimprisonment set forth in subsection e. ofN.J.S.2C:44-1 for personswho have not previously been convicted of an offense shall not apply. Notwithstanding the

16 I informed Mr. Dimakus that there was no stamp with the exact time of filing or an attached receipt on thedefendants' motion to dismiss my (plaintiff's) complaint and I asked him if he had detached the receipt, heresponded, No then 1 asked him ifhe could provide me with the copy of the defendants' motion to dismiss whichprobably they had in Judge Doyne's chamber, but he said they did not have any copy in their office. Therefore 1asked Mr. Dimakus, if there was no copy of the defendants' motion to dismiss with the exact time offiIing or therewas no receipt of filing attached to defendants' motion to dismiss in the Court, how judge Doyne knew that myrequest for entry of default had been filed subsequent to the defendants' motion to dismiss, Mr. Dimakus responded,I do not know .

17 Not to mention that the defendants' motion to dismiss the plaintiff's verified amended complaint was filed after thedate that the answer to verified amended complaint was due which consequently could not toll the time to answerthe verified amended complaint and accordingly defendants were in default and after the entry of default, defendantshad no right to any defense except filing a timely motion ,~ vacate the default before a motion for default judgmentbe filed.



IRANDOKHT TOORZANIPL~TIFF,Prose175 oxford fer. 2River Edge, New Jersey 07661


provisions ofN.J .S.2C: 1-8 or any other law, a conviction of pattern of official misconduct shallnot merge with a conviction of official misconduct, official deprivation of civil rights, or any othercriminal offense, nor shall such other conviction merge with a conviction under this section, andthe court shall impose separate sentences upon each violation ofN.J.S.2C:30-2 and sections 2 and3 ofP.L.2003, c.31 (C.2C:30-6 and C.2C:30-7).2C:30-2. Official misconduct: A public servant is guilty of official misconduct when, withpurpose to obtain a benefit for himself or another or to injure or to deprive another of a benefit:a. He commits an act relating to his office but constituting an unauthorized exercise of his officialfunctions, knowing that such act is unauthorized or he is committing such act in an unauthorizedmanner; orb. He knowingly refrains from performing a duty which is imposed upon him by law or is clearlyinherent in the nature of his office.Official misconduct is a crime of the second degree. If the benefit obtained or sought to beobtained, or of which another is deprived or sought to be deprived, is ofa value of $200.00 or less,the offense of official misconduct is a crime of the third degree.

By writing this report I am hoping that the Bergen County prosecutor uses his authorityunder the NJ Statutes to take appropriate actions in regard to the above violation of laws andcriminal conducts.

criminal complaint filed with the bergen county prosecutor's office against the officers of the...

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