Legal Document: Franklin Lakes Affor Vs Vance Bradford

On March 07, 2023 a TRACK ASSIGNMENT Notice submitted by Case Management was filed involving a dispute between Franklin Lakes Affordable, and Bradford Vance, Marina Vance, for Tenancy in the District Court of Bergen County.

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ANTHONY J. BRADY, JR., ESQUIRE
1 Rose Avenue
Maple Shade, New Jersey 08052
(561) 603-6387.
Attorney for Plaintiffs
Bar Number 044541984

Franklin Lakes Affordable Reality, LLC. SUPERIOR COURT OF NEW JERSEY
BERGEN COUNTY
Plaintiff SPECIAL CIVIL PART
vs. Landlord/ Tenant

Bradford and Marina Vance DOCKET NO. BER-LT-001291-23

Defendants. ORDER For Dismissal.

IT IS ON THIS ______ Day of ___________ held that the above eviction action be dismissed with

prejudice for violation of N.J.Ct.R. 4-5 and 4:30A and/or material misrepresentations to the Court.

__________________________

J.S.C.
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Franklin Lakes Affordable Reality, LLC. SUPERIOR COURT OF NEW JERSEY
BERGEN COUNTY
Plaintiff SPECIAL CIVIL PART
vs. Landlord/ Tenant

Bradford and Marina Vance
DOCKET NO. BER-LT-001291-23.
Defendants.
CERTIFICATION OF ANTHONY J BRADY JR.

My name is Anthony Brady and hereby certify as follows
I. I represent Bradford Vance the Defendant in the above.
2. The matter involves a frivolous eviction action and a continuing civil rights violation for Mr.
Vance’s continuing assertion of his civil rights.
3. Prior to the instant suit being filed Mr. Vance filed a suit in the Law Division entitled Vance v
Louis Friedman and Franklin Lakes Affordable Housing.
4. Vance action was filed on February 27, 2023. Att 1.
5. Notice of the suit was emailed to Attorney Gudin with a copy of the complaint. Att 2.
6. Vance’s’ suit requests a declaratory judgment, injunctive relief and damages arising as the
same facts alleged in the pending eviction action. Att 1 and Att 3.
This suit was filed on March 7, 2023 which a false certification asserting the matter was not the
subject of a pending suit signed by Mr. Friedman the CEO of the Apartment Complex. Att 3
page 12.
7. Material Misrepresentations to this Court are nothing new. Mr. Friedman and counsel made
numerous misrepresentation before Judge Rosa including that Vance had exposed himself to a
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minor and owned back rent. Possibility a film was tampered with having a Rosemary woods type
of gap. Friedman also gave false information to the police. Att 3. Vance seeks dismissal under
the single issue controversy doctrine R 4. 5 and N.J. Ct. R. 4:30A

I hereby certify the foregoing statements by are true. If they are willfully false I am subject to
punishment.
s/A. Brady
Anthony J Brady Jr.
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ANTHONY J. BRADY, JR., ESQUIRE
1 Rose Avenue
Maple Shade, New Jersey 08052
(561) 603-6387.
Attorney for Plaintiffs
Bar Number 044541984

Franklin Lakes Affordable Reality, LLC. SUPERIOR COURT OF NEW JERSEY
BERGEN COUNTY
Plaintiff SPECIAL CIVIL PART
vs. Landlord/ Tenant

Bradford and Marina Vance
DOCKET NO. BER-LT-001291-23
Defendants. MEMORANDUM OF LAW
OF LAW

FACTS:

Bradford Vance relies on the facts of the certification of Brady.

LEGAL ARGUMENT ONE.

THIS EVICTION SHOULD BE DISMISSED WITH PREJUDICE FOR THE LANDLORD
VIOLATION OF R 4. 5 AND R. 4:30A AND/OR FOR ITS MATERIAL
MISREPRESNTATION TO THIS COURT.

It is respectfully submitted that the above action should be dismissed with prejudice for violation
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of Court Rules 4.5 and R. 4:30A.as well as its material misrepresentations to this Court.

Respectfully submitted,

.s/A Brady
A Anthony Brady Jr.
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ANTHONY J. BRADY, JR., ESQUIRE
1 Rose Avenue
Maple Shade, New Jersey 08052
(561) 603-6387.
Attorney for Plaintiffs
Bar Number 044541984

Bradford Vance, SUPERIOR COURT OF NEW
JERSEY
Plaintiff BERGEN COUNTY
LAW DIVISION
vs.
Louis Friedman, DOCKET NO. BER -
Franklin Lakes Rlty LLP.
And or Franklin Lakes Affordable
Reality, LLC.
John Doe(s) A thru Z.

Defendants

Plaintiff Bradford Vance residing at 558 Colonial Road, Apt 204, Franklin Lakes, NJ

0741 residing at by way of complaint against the Defendants’ states:

PARTIES.

1. Bradford Vance is disabled, is an Armenian Jew and a son of a Soviet immigrants (hereafter

referred to as BV).

2. Louis Friedman is the principle of Franklin Lakes Rlty LLP and/ or Franklin Lakes

Affordable Reality, LLC. is an apartment complex located at 556 and 558 Colonial Road, Apt

417, Franklin Lakes, New Jersey 7417-1384. (herein after called the Laqndlord

along with Defendant Friedman).

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FACTS.

3. (BV) is a tenant at Landlords. His address is 558 Colonial Road, Apt 204,

Franklin Lakes, NJ 07417 In 2016, to secure his tenancy, BV had to file a complaint with

the New Jersey Division of Civil Rights under Docket number HN16NB65769 because

of discrimination BV was successful.

4. Since that time Landlord and its employees agents entered into a pattern of retailation

against BV.

5. On July 12, 2022 BV was involved in an extremely serious motor vehicle accident. The

accident caused his fathers’ motor vehicle to be totaled with $46,000.00 in property damage.

As a result BV struck his head becoming unstable, irrational and of unsound mind.

6. He discovered he is not in the possession of his key.

7. BV requested that his landlord let him in. Out of spike the Landlord employee Cathleen

Foster informed BV to open the door would cost him $100.00, notwithstanding, the lease

indicated the cost would be $25.00 and that employees of the apartment routinely would

open locked doors without costs. .

8. Due to the accident BV acted irrationally/without a sound mind. He attempted to enter his

apartment door with his cane striking the lock causing diminutive indentations of the

aluminum door.

9. The Landlord had a security tape that recorded the incident which has been

supplied to Plaintiff BV by Franklin Lakes Borough.

10. As will be discussed in detail below the Landlord and its

Employees/ agents withheld exculpatory evidence of a 26 seconds section of the tape

which would have shown that Landlord and its principle Defendant Friedman

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allegation that BV exposed himself to a minor child is a material.

misrepresentation of fact to the New Jersey Superior Court under its eviction complaint.

11. Plaintiff BV, pursuant to his freedom of speech and the philosophy of google, placed a

google negative review, of the Landlord and a number of persons. BV did not threnten

violation of any mention and made no mention of sexual conduct. Moreover, the statements

in the review were truthful.

12. Defendant Landlord and Friedman proceeded with a two

front approach unethical insidionals prosecution of Plaintiff BV.

13. Specially, Defendant Landlord filed a complaint in the Superior Court of

New Jersey Special Civil Part for eviction DK number Ber LT 4403- 22 . In the Complaint

which Defendant Friendman and his attorney Bruce Gudin vertified it is specially stated “

At approximinatey 3:44 p.m. you undressed and exposed yourself to a small child” …

14. The allegation in the complaint was signed by a member of the New Jersey Bar Bruce Gudin

and vertified by Defendant Friedman.

15. The security tape, supplied by the Defendant Franklin Lakes parties, tell a different story.

The tape shows Plaintiff in acute distress. At 3:44 01 the tapes indicates the suddon/

involuntary drop of BV’s basketball warm up pants, excsposing basketball shorts.

Plaintiff, promptly leaned over to pull his basketball warm up pants up.

16. Immediately Plaintiff BV adjusted his pants which difficulties because of his disability.

24.By 3:44 16-17 the pants were fooly covering his legs; At 3:44-18-19 a family entered the

hallway. At 3:44-20 the tape is earsed for 26 seconds.

17. During the 26 seconds Plaintiff BV had a nice conversion with the mother of the children.

18. At all times Plaintiff BV had his genitalia covered. He had at all times basketball type

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shorts.

19. The Defendant’s allegation in its complaint is false and malicious and was used to

attempt to evict Plaintiff in violation of due process and Plaintiffs’ property rights

under the 5th and 14th amendments of the Federal Constitution as well as the New Jersey

Constitution. Art 1 para 1.

20. The Landlord and its agents engaged in a second front with the Franklin

Lakes Defendants.

21. Defendant Friedman on July 13, 2022 contacted the Franklin Police

Department to make a complaint against Plaintiff for the incident of July 12, 2022

The officer assigned was Christopher O’Brien who opened a file.

22. Defendant Louis Freidman took this action to gain a civil advantage in his eviction action

against Plaintiff BV.

The evidence supplied to O’Brien having a 26 seconds gap of a tape, which

would serve as exculpatory evidence for Plaintiff BV.

23. O’Brien make an inadequate report writing Plaintiff BV dropped his pants

in front of a woman. The film indicates the basketball warm up pants came down

involuntary and it was not in front of a woman.

24. Officer ’Brien in a joint action with the Apt Defendants’ filed a cybercrime against Plaintiff

BV for a negative review on google concerning the Apts.

The review specially stated, “Let’s start off by saying all these reviews are fake. Only

local guides are real. Both “Kathy a d@n are users. Rats all over the garage. Buildings

smells like trash. Nowhere to your dogs out. Awful community gross and pathetic. Can’t

afford a real mansion in Franklin Lakes. D@n drinks and drives and consumes cannabis

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in front of building so it always smell mid pot and other nefarious things. . Needles all

over. Building is falling apart. If ur in the market for a place go to “the Franklin “better

location much better amenities.

25. Of note, there is no mention of violence or sexual activity. Officer O’Brien charged BV with

cybercrime.

26. By the plain language of 2C:33-4.1 the offense requires a threat of violation or posting of

sexual content. The plain language has been affirmed by the courts. v. Carroll, 456 N.J.

Super. 520, 535 (App. Div. 2018).

27. The Bergen County Prosecutor declined to prosecute Plaintiff BV.

28. On July 12, 2022 officer Hill of the Franklin Lakes police Department advised Plaintiff V

that he is not to enter building at 556 or he would be charged with trespassing.

29. On September 2, 2022 Plaintiff BV served a tort claim notice upon the Franklin Lakes

notifying the Defendants that pursuant to the lease BV had a property right to

use the gym and patio at apartment building 556.

30. On Sunday September 4, 2022 Plaintiff BV was peacefully relaxing on the patio at the 556

building pursuant to his property right and lease. Three Franklin Police cars appeared at the

property and charged BV. Officers charged with their hands next to their firearms. Some

officers put gloves on as to make an arrest.

31. In a gruff tone of the police including Sergeant Kline and Officer Heffner

ordered him to immediately leave and if he returned he would be arrested for criminal

trespass.

32. Apparently, the landlord entities misinformed the police and/or the police failed

to conduct an elementally investigation.

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33. After July 12, 2022 the Defendant Apt entity deactivated Plaintiff BV, which hinders his

ability to gain entrance to his apartment building.

34. The police actions denying his access to his property upon threat of criminal prosecution

and the denial of access to a front door without due process of law is a self-eviction.

35. As plead in paragraph 14 the Landlord filed an action in New Jersey Special Civil Part for

eviction under DK number Ber LT 4403- 22.

36. Because of the above action BV filed an action in the Superior Court of New Jersey Law

Division asserting numerous civil rights violations and numerous causes of action

under Docket number Ber -004860-22.

37. By motion the BV attempted to remove the Landlord Tenant matter by motion to the Law

Division but was denied by Judge Rosa JSC. The New Jersey Appellate Division granted

Vances’ leave to appeal the Landlord Courts’ denial under Docket A-610-22

38. Both matters are pending and after filing this new action Vance will seek leave to consolidate

the matters.

39. On February 1, 2023 Defendant landlord entered Vances apartment despite being in

litigation. Landlord Friedman or their counsel did not notify Vances’ attorney of the intended

intrusion notwithstanding the litigation.

40. Upon information and belief the Landlord did not give notice by mail nor by other means

such as email or telephone.

41. Attorney Gudin has declined to supply any proof of service thou requested.

42. Upon return to his apartment Vance found the apartment was ransacked. On the door there

was no notice of an intended inspection but on the door there was a notice that the apartment

was inspected and “everything good.”

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43. On February 25, 2023 Vance received in the mail a notice to quit and notice for possession

based on a removal, disabled and discard of a smoke and carbon monoxide detector. There

was an allegation of theft. There also an allegation of marijuana smoke smell. The notice

requied he leave his tenancy by February 26, 2023 a Sunday.

44. The notice instructed for a demand for possession signed by attorney Gudin. Previously, Mr.

Gudin had signed a false verified complaint asserting Mr. Vance had exposed himself to a

minor.

45. The latest allegation is false. Because of a malfunctions smoke detector in the bed room

Vance requested landlord to examine it . An employee disconnected the alarm with the

promise he would replaced same. He left the alarm in the same bedroom as well a ladder.

he did not replace the alarm. None of the other alarms were touched.

46. With due diligence counsel for the Landlord with a simple telephone call to Vance’s’ counsel

could have discovered the issue of the smoke detector.

47. Vance has not smoked in his apartment.

48. There are no other allegations of misuse of smoke detectors of the apartment.

49. The February allegations by Landlord and Friedman are the latest retaliation for the

foregoing asserting of civil rights by Vance.

50. As a result, Vance sustained emotional distress.

51. He seeks a ruling from this court that the entry to his property was illegal as well as he did

not steal nor disconnect his smoke alarm.

52. He also seeks an injunction that the constant harassment because his exercise of civil rights.

53. Vance also seeks damages including putative.

54. Vance intends to file a motion to consolidate this matter with the pending suit in that the

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Landlord and Friedman are engaging in a pattern of discrimination.

55. The actions were negligent and or grossly negligent and or intentional and wilfull

Wherefore, Plaintiff Vance demand judgment for:

1. A declaratory judgment holding that the Defendants’’ illegality entered Plaintiffs’

apartment and that Plaintiff did not willfully or with gross negligence damaged any

smoke detectors or steal same. .

2. An injunction for Defendants to stop the ongoing discrimination and harassment

3. Damages including putative.

4. Attorney fees and Costs.

Second Count.

Plaintiff repeats the allegations of the first count.

56. John Doe(s) A thru Z. are fictitious names of Defendants.

57. Said Defendants are names of persons businesses institutions that are also

responsible for the aforementioned acts which are unknown at the time.

Wherefore, Plaintiffs demand judgment against John Doe(s) A thru Z for:

1. A declaratory judgment holding that the Defendants’’ illegality entered Plaintiffs’

apartment and that Plaintiff did not willfully or with gross negligence damaged any

smoke detectors or steal same.

2. An injunction for Defendants to stop the ongoing discrimination and harassment

3. Damages including putative.

4. Attorney fees and Costs.

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Plaintiff demands a trial by jury.

s/ Anthony J. Brady Jr.
Dated: February 25, 2023.

ANTHONY J. BRADY, JR., ESQUIRE
Attorney for Plaintiffs

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Civil Case Information Statement
Case Details: BERGEN | Civil Part Docket# L-001081-23

Case Caption: VANCE BRADFORD VS FRIEDMAN LOUIS Case Type: CIVIL RIGHTS
Case Initiation Date: 02/27/2023 Document Type: Complaint with Jury Demand
Attorney Name: ANTHONY JAMES BRADY JR Jury Demand: YES - 6 JURORS
Firm Name: ANTHONY J. BRADY Is this a professional malpractice case? NO
Address: 241 BURGUNDY F Related cases pending: YES
DELRAY BEACH FL 33484 If yes, list docket numbers: A 0610 22 Ber LT 4403 22 and Ber law
Phone: 5616036387 4840 22. Intent to file motion to consolidate.
Name of Party: PLAINTIFF : Vance, Bradford Do you anticipate adding any parties (arising out of same
Name of Defendant’s Primary Insurance Company transaction or occurrence)? NO
(if known): Unknown Does this case involve claims related to COVID-19? NO

Are sexual abuse claims alleged by: Bradford Vance? NO

THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE
CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION

Do parties have a current, past, or recurrent relationship? YES
If yes, is that relationship: Other(explain) Landlord-tenant
Does the statute governing this case provide for payment of fees by the losing party? YES
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
yes plaintiff requests a management a conf due to complicated issues and ongoing discrimination.

Do you or your client need any disability accommodations? NO
If yes, please identify the requested accommodation:

Will an interpreter be needed? NO
If yes, for what language:

Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO

I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)

02/27/2023 /s/ ANTHONY JAMES BRADY JR
Dated Signed
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Anthony Brady Mon, Feb
27,
2:56 PM
to Laurie, Raina, Esquire, Bruce, me, bcc: bvance55, bcc: Gary, bcc: Christina

Dear Counsel, I attach a copy of a new complaint filed today concerning the recent civil
rights violations from February, 2023. I need to file a motion to consolidate. Do I have
your consent?
I also intend to file a motion to amend the complaint to add the property apartment entity
and add a negligence count after again reading the transcript . Again do I have your
consent? In regard to the Fair Housing Suit it involves all three buildings on the property
just not the apartment that Mr. Vance is a tenant . I doubt the Franklin Lakes Affordable
Housing entity owns the other two buildings. Please advise in order that I may include
the property entities.
In regard to discovery I note that parties have 60 days to serve answers not the 30 days
as contained in the letter. The matter is not in federal court or another state. I note the
production of document request was not done pursuant to NJ rules. However, i met with
two of my clients and hope to have a respond within ten days. In regard to depositions I
am on holiday on the dates selected.. Pick dates in April. I will not depose at this time
any police officers because the time is not ripe. Of course he can depose my clients at a
mutually convenient time but please keep in mind the Defendant will only get one bite at
the apple. I also intend to ask the court for a conference. The briefs in the Appellate
Court have been filed thou I have to make a minor adjustment to the reply. I attach the
briefs and a published opinion from a federal court to describe the environment I have
dealing with. Thank you for your kind attention, Anthony Brady 561 603 6387
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2:54:09
3:27:56
PgPM
PM
27 ofPg
Pg
114
77of
ofTrans
52
47 Trans
Trans
ID: LCV20232173043
ID:
ID:SCP20231147586
SCP2023692433
BER-LT-001291-23
BER-LT-001291-23
BER-L-003900-23
04/17/2023
03/07/2023
04/17/2023
2:54:09
3:27:56
PgPM
PM
28 ofPg
Pg
114
88of
ofTrans
52
47 Trans
Trans
ID: LCV20232173043
ID:
ID:SCP20231147586
SCP2023692433
BER-LT-001291-23
BER-LT-001291-23
BER-L-003900-23
04/17/2023
03/07/2023
04/17/2023
2:54:09
3:27:56
PgPM
PM
29 ofPg
Pg
114
99of
ofTrans
52
47 Trans
Trans
ID: LCV20232173043
ID:
ID:SCP20231147586
SCP2023692433
BER-LT-001291-23
BER-LT-001291-23
BER-L-003900-23
04/17/2023
03/07/2023
04/17/2023
2:54:09
3:27:56
PgPM
PM
30 of
Pg
Pg114
10
10of
of
Trans
52
47 Trans
ID:
Trans
LCV20232173043
ID:
ID:SCP20231147586
SCP2023692433
BER-LT-001291-23
BER-LT-001291-23
BER-L-003900-23
04/17/2023
03/07/2023
04/17/2023
2:54:09
3:27:56
PgPM
PM
31 of
Pg
Pg114
11
11of
of
Trans
52
47 Trans
ID:
Trans
LCV20232173043
ID:
ID:SCP20231147586
SCP2023692433
BER-LT-001291-23
BER-LT-001291-2

Case Info

Judge

Peter G Geiger Track Judge’s New Case

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Document Filed Date

July 26, 2023

Case Filing Date

March 07, 2023

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Document for Franklin Lakes Affor Vs Vance Bradford

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