Preview
SOM-L-000003-24 01/02/2024 Pglof23 Trans ID: LCV20242787
LAW OFFICES OF
STEVEN A. GARNER, LLC
100 Franklin Square Drive Tel; (732) 356-1450
Suite 205 Fax: (732) 356-1451
Somerset, NJ 08873 steven@stevengarnerlaw.com
December 22, 2023
Manager, Criminal Division
Attn: Motions Clerk
Somerset County Courthouse
20 North Bridge Street
Somerville, NJ 08876
Re: State of New Jersey v. Hector Morente Lope
Motion to Consolidate under Rule 7:8-4
South Bound Brook Municipal Court and
Bound Brook Municipal Court
Dear Sir/Madam:
With regard to the above-referenced matter, please find enclosed an original and
one (1) copy of the following:
1 Notice of Motion
2. Certification
3. Proposed Form of Order
Kindly return a filed copy of this document to this office in the self-addressed
stamped envelope provided for your convenience.
Thank you for your attention in this matter.
Yours truly,
Steven A Garner
Steven A. Gamer, Esq.
Attorney for Defendant
encls.
cc: Honorable Kevin Shanahan, J.S.C.
SOM-L-000003-24 01/02/2024 Pg2o0f23 Trans ID: LCV20242787
Steven A. Garner, Esq. (#002582003)
100 Franklin Square Drive - Suite 205
Somerset, New Jersey 08873
(732) 356-1450 (tel.)
(732) 356-1451 (fax)
Attorney for Defendant
} SUPERIOR COURT OF NEW JERSEY
STATE OF NEW JERSEY, ) SOMERSET COUNTY
) CRIMINAL DIVISION
Plaintiff, )
) SOUTH BOUND BROOK MUNICIPAL COURT
VS, ) COMPLAINT.NO.: S-23 2023-0000-14
) SUMMONS NOS.: E23-000970 to E23-000976
and
HECTOR MORENTE LOPEZ, ) BOUND BROOK MUNICIPAL COURT
) SUMMONS NOS.: SC-14445 to SC-14448
Defendant. ) NOTICE OF MOTION FOR
) CONSOLIDATION
TO. Honorable Kevin Shanahan, J.S.C. Criminal Division Manager’s Office
Assignment Judge Attn: Motions Clerk
Somerset County Superior Court Somerset County Courthouse
20 North Bridge Street 20 North Bridge Street
Somerville, NJ 08876 Somerville, NJ 08876
Bound Brook Municipal Court Bound Brook Municipal Prosecutor
230 Hamilton Street 230 Hamilton Street
Bound Brook, NJ 08805 Bound Brook, NJ 08805
South Bound Brook Municipal Court South Bound Brook Prosecutor
12 Main Street 12 Main Street
South Bound Brook, NJ 08880 South Bound Brook, NJ 08880
PLEASE TAKE NOTICE that at a time and date to be set by the Court, that the
undersigned, attorney for defendant Hector Morente Lopez, will move before the Somerset
County Superior Court, located at 20 North Bridge Street, Somerville, New Jersey, seeking an
Order to Consolidate the defendant’s matters in the South Bound Brook Municipal Court
(Summons Numbers E23-000970 through E23-000976, along with §23-2023-14 and $23-
SOM-L-000003-24 01/02/2024 Pg3o0f23 Trans ID: LCV20242787
2023-17) and the Bound Brook Municipal Court (Summons Numbers SC-14445 to SC-
14448), to be consolidated for trial in the South Bound Brook Municipal Court, as these
involve a common question of law or fact arising out of the same facts or circumstances,
under Rule 7:8-4,
Counsel requests a hearing pursuant to R.3:10 if there is any opposition to this motion.
Dated: December 22, 2023 By, Steven A Guracr
Steven A. Garner, Esq.
Attorney for Defendant,
Hector Morente Lopez
CERTIFICATION OF SERVICE
I hereby certify that this Motion was sent to the above-captioned individuals on this
date.
Dated: December 22, 2023 By: StevenA Garner
Steven A. Garner, Esq.
Attorney for Defendant,
Hector Morente Lopez
SOM-L-000003-24 01/02/2024 Pg4of23 Trans ID: LCV20242787
Steven A. Garner, Esq. (#002582003)
100 Franklin Square Drive — Suite 205
Somerset, New Jersey 08873
(732) 356-1450 (tel.)
(732) 356-1451 (fax)
Attorney for Defendant
) SUPERIOR COURT OF NEW JERSEY
STATE OF NEW JERSEY, ) SOMERSET COUNTY
) CRIMINAL DIVISION
Plaintiff, )
) SOUTH BOUND BROOK MUNICIPAL COURT
VS. ) COMPLAINT NO.: 8-23 2023-000014 and 17
) SUMMONS NOS. :; E23-000970 to E23-000976
and
HECTOR MORENTE LOPEZ, ) BOUND BROOK MUNICIPAL COURT
) SUMMONS NOS.: SC-14445 to SC-14448
Defendant. ) ORDER
)
This matter having been opened to the Cowt upon motion of Steven A.
Garner, Esq., attorney for defendant for an Order for Consolidation, and the Court
having considered the annexed letter brief, if any, oral argument, and the rule of law,
and for good cause shown,
Ttis on this day of » 2024
ORDERED that defendant’s matters in the South Bound Brook Municipal
Court (Summons Numbers E23-000970 through E23-000976, along with $23-2023-
14 and $23-2023-17) and the Bound Brook Municipal Court (Summons Numbers
SC-14445 to SC-14448) are hereby consolidated for trial in the South Bound Brook
Municipal Court, and
FURTHER ORDERED that a copy of this Order shall be served upon all
Parties within ten (10) days.
Dated:
JSC.
SOM-L-000003-24 01/02/2024 Pg5of23 Trans ID: LCV20242787
Steven A. Garner, Esq. (#002582003)
100 Franklin Square Drive — Suite 205
Somerset, New Jersey 08873
(732) 356-1450 (tel.)
(732) 356-1451 (fax)
Attorney for Defendant
) SUPERIOR COURT OF NEW JERSEY
STATE OF NEW JERSEY, ) SOMERSET COUNTY
) CRIMINAL DIVISION
Plaintiff, )
) SOUTH BOUND BROOK MUNICIPAL COURT
vs ) COMPLAINT NO.: 8-23 2023-0000-14
) SUMMONS NOS.: E23-000970 to E23-000976
and
HECTOR MORENTE LOPEZ, ) BOUND BROOK MUNICIPAL COURT
) SUMMONS NOS.: SC-14445 to SC-14448
Defendant. } CERTIFICATION FOR MOTION
) FOR CONSOLIDATION
I, STEVEN A, GARNER, ESQ., of full age, hereby certify as follows:
1 1 am the attorney for the Defendant in the above-captioned matter, am
fully familiar with the facts of this case and am authorized to make this Certification,
2. On August 18, 2023, the Defendant, Hector Morente Lopez, was charged
with various motor vehicle violations while traveling through the adjacent towns of South
Bound Brook, New Jersey and Bound Brook, New Jersey, with both towns being located
in Somerset County.
3 The South Bound Brook Police Incident Report (#23234292) indicates
that the officer involved was “traveling North on South Main Street in Bound Brook
Borough” when his “patrol unit was struck by a silver pickup truck that had crossed into
the Northbound Lane of travel as it was traveling South.” The officer “maneuvered his
vehicle around and caught up to the silver pickup truck which was a Ford F-150, silver in
color, bearing NI registration, GA(ONNW and activated his lights and siren.” The officer
SOM-L-000003-24 01/02/2024 Pg6of23 Trans ID: LCV20242787
had pursued the vehicle “North over the Queens Bridge” and after some time “the vehicle
stops at the red light.” A DWI investigation began afier that. (Please see the incident
report for the officer’s further details.)
4 The South Bound Brook Police Department later issued tickets to the
Defendant with Summons Numbers E23-000970 through E23-000976, along with S23-
2023-14 (SBB Borough Ordinance 3-9.6 Interfering with Borough Officials) and $23-
2023-17 (SBB Borough Ordinance 3-9.8 Fleeing from Police Officer). (Please see
Summonses provided.)
5 The Bound Brook Police Department later issued tickets to the Defendant
with Summons Numbers SC-14445 to SC-14448. (Please see Summonses provided.)
6 Under Rule 7:8-4, “The court may order two or more complaints to be
tried together if the offenses arose out of the same facts and circumstances, regardless of
the number of defendants. In all other matters, the court may consolidate complaints for
trial with the consent of the persons charged. A party seeking consolidation Complaints
originating in two or more municipalities may be consolidated for trial only with the
approval of the appropriate Assignment Judge, who shall designate the municipal court in
which trial is to proceed. A party seeking consolidation of complaints originating in
different municipalities shall file a written motion for that relief directly with the
Assignment Judge.”
7. These two matters in South Bound Brook and Bound Brook involve the
ame facts and circumstances in that these incidents were all part of one continuous
motor vehicle operation on the same date one after the other. The driver was not shown
to have left or stopped his vehicle in between these incidents. It was really one
continuous offense that took part through two separate towns via connecting roads.
8 These should all be heard in one court, namely the South Bound Brook
SOM-L-000003-24 01/02/2024 Pg7of23 Trans ID: LCV20242787
Municipal Court, for judicial economy of the Courts’ time and resources rather than the
same facts and circumstances in two separate courts for similar charges. This also should
be heard in one court in fairness to the Defendant who committed one act or series of
acts, but through two independent towns. The Defendant and the Court should have an
opportunity to arrive at a global resolution of all charges knowing all the facts and
circumstances of this incident at one time. The Prosecutor in Bound Brook Municipal
Court has consented to this and it is the same Judge, namely the Honorable Michael
Fedun, J.M.C., who sits in both Municipal Courts. As such, we are asking that these
matters be consolidated with both matters heard at the same time.
I certify that the foregoing statements made by me are true. | am aware that if any
of the statements made by me are willfully false, 1 am subject to punishment.
Dated: 12/22/2023 By: Stoven Ah Garner
Steven A. Garner, Esq.
Attorney for Defendant,
Hector Morente Lopez.
SOM-L-000003-24 01/02/2024 Pg 8of23 Trans ID: LCV20242787
e SOUTH BOUND BROOK POLICE
SOUTH BOUND BROOK, NJ
Incident # 23234292
Summary
felitecimacs
INCIDENT APP I
ae 104
On 08/18/2023 at approximately 22:00 hours while waveling Noxth on South Main Street in Bound Brook Borough
in the area of 50 S. Main Street, my patrol unit was struck by a silver pickup truck that had crossed into the
Northbound Lane of travel as it was traveling South, Note: ‘This Officer was about to initiate a motor vehicle stop and
my dashcam had already been activated capturing the motor vehicle collision with sound,
Please refer to Bound Brook PD accident report case 23013072,
As I looked in my mirror immediately after the collision, I observed the silver pickup truck continuing South as it
passed two parking lots 50 S. Main Street and 69 S. Main Street. I maneuvered my vehicle around and began driving
[North over the Queens Bridge to catoh up with the silver pickup truck, at this time my overhead lights were
activated. In the area of Main Street and Canal Rd, 1 observed the same pickup truck which was a Ford F-150, silver
in color, beating NJ registration, G4ONNW and activated my lights and siren. The defendant's vehicle turned right
fiom the Queens Bridge onto Canal Road, As the vehicle made the wide right-hand turn it entered into the Eastbound
Lane of travel and continued West down Canal Road. As the vehicle was traveling West on Canal it continued West
in the Eastbound Lane for approximately one block from Canal Rd. and Main St, to Elizabeth and Canal Road as the
vehicle straddled the double yellow line, The suspect vehicle also had his left turn signal on and never turned feft
onto Elizabeth Street, While the vehicle continued West I was communicating with dispatch notifying them the
vehicle was failing to stop traveling at a safe speed, Notifying dispatch of my speed as I followed the vehicle and of
my current location the vehicle continued to not stop. In the area of Canal Rd. and Van Sickle Blvd, the vehicle
traveled over the center fine. In the area of Canal Rd. and Equator Ave., the vehicle crossed over the white fog line.
In the area of Canal Rd. and Jerome Ave. the vehicle orossed over the white line and xemains driving over the white
line for approximately one block until it reaches the area of Canal Rd. and Howard Ave. where the rear passenger
side tire touches the dirt and grass leaving the roadway. In the area of Canal Rd. and Sanders Ave, the vehicle crosses
over the white line and uses its left turn signal again however, continues straight, In the area of Weston Canal Rd,
and Route 287 the vehicle stops at the red light. As I exit my marked patrol unit, | observed the defendant later
identified as Hector L. Morente-Lopez, swaying his head and yelling “what , what, what” as I ordered him out of the
vehicle. I opened the defendant’s vehicle and I could immediately detect the odor of an alcoholic beverage emitting
fiom the defendant. I also observed the defendant’s eyes were watery and bloodshot red. I guided the defendaut out
of the vehicle at which time he fell due to poor balance, I placed the defendant in handcuffs at this time for safety.
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SOM-L-000003-24 01/02/2024 Pg9of23 Trans ID: LCV20242787
SOUTH BOUND BROOK POLICE
SOUTH BOUND BROOK, NJ
Incident # 23234292
Summary
iter Tee
Around this time, Ofc. Kieslor, Ofc. Rodriguez Bound Brook PD, Ofc. Sabal BBPD, Sgt. Wertheim BBPD arrived
on scene, as backup. Of. Kieslor contacted Sgt. Savitt who later responded to the scene as he was at headquarters as
his shift had just ended. Two Frankdin Twp. Officers also responded to the scene.
While on scene Ofc. Rodriguez was advised of the sequence of events for the accident report and later provided ail
Necessary documents to complete the accident report.
Artest Decision:
Based on the following information, I formed the opinion the defendant was under the influence. The defendant
operating the yehiele that suck my marked patrol unit and fled the scene, The defendant failing to stop for this
officer whose emergency lights and sirens were activated for an extended period of time. The defendant failing to
turn/improperly using his turn signal multiple times. The defendant’s bloodshot watery eyes, and the strong odor of
an alcoholic beverage emitting from the defendant and Iris breath. The defendants erratic driving behavior, the
defendant failing to maintain his lane repeatedly. T arrested the defendant for suspicion of DWI. The defendant was
searched incident to arrest and placed in the rear of my patrol vehicle. Somerset Hills Towing responded to tow the
vehicle.
While at HQ:
The defendant was removed from the rear of the police vehicle. There was the smell of ati alcoholic beverage coming
from the rear of the patrol vehicle that was not there prior to placing the defendant there, The defendant was brought
inside police headquarters to the booking area where he was again searched and secured to the booking bench. The
defendant was read the NJ Attorney General's Standard Statement for DWI by Ofc. Rodriguez in Spanish. The
defendant replied, "No" to providing breath samples. A 20-minute observation period was still conducted and the
defendant was issued the refusal for refusing to provide breath samples. During that time the defendant did not
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SOM-L-000003-24 01/02/2024 Pg10o0f23 Trans ID: LCV20242787
SOUTH BOUND BROOK POLICE
SOUTH BOUND BROOK, NJ
Incident # 23234292
Summary
Oiler lere)}
ingest, regurgitate, or placed anything inside of his mouth. Sgt. Savitt administered the Alcotest for the refusal,
Upon completion of the Alcotest, the defendant was read the Miranda form in English which he relayed he
understood, The defendant later refused to sign the Miranda form and when questioned on the drinking questionnaire
form, he relayed his “lawyer will take care of this”. The defendant’s brother Marvin Morente-Lopez was contacted
and responded to headquarters where he signed a Potential Liability Warning form, Marvin was given a copy of the
paperwork, The defendant was then released under the care of his brother, Note: The defendant would continue to
say le understood English than that he did not, Sgt. Savitt, Ofc. Kieslor, and Ofc, Rodviguez were all al HQ during
this time.
Sgt. Savitt notified Lt. LaGrua of this incident.
Motor Vehicle Violations and Borough Ordinances Issued:
£23000970 39:4-50 DWI
823000971 39:4-50,.4A Refusal
23000972 39:4-88A Traffic marked lanes nearest right
E23000973 39:4-88C Traffic marked lanes center lane violation
23000974 39:4-96 Reckless Driving
23000975 39:4-97 Careless Driving
E23000976 39:4-9{ Failure To Yield Right Of Way To Emergency Vehicles
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SOM-L-000003-24 01/02/2024 Pg1lof23 Trans ID: LCV20242787
SOUTH BOUND BROOK POLICE
SOUTH BOUND BROOK, NJ
Incident # 23234292
Summary
fei inicio)
* $232023000014 SBB B.O, 3-9.6 Interfering with Borough Officials
+ §232023000017 SBB B.O. 3-9.8 Fleeing from Police Officer (Mailed on 08/20/2023).
The following complaints for title 39 violations were signed with the Bound Brook Borough Municipal Court on
08/24/2023 at approximately 13:45 hours. All tickets were later mailed to the defendant.
18044076576 39:4-97 Careless Driving
18044076577 88.B Failure to keep right
1804A076578 130 Failure to report an accident
18044076579 39:4-[29 Leaving the scene of an accident
The defendant was provided all copies and mailed B.O, #8232023000017,
ATS/ACS/NCIC all checked, negative results,
ce} ect PLC)
REPORTING OFFICER: DATE/TIME ENTERED
ore IRO LOWDER (1946 ) -18-:
Ri
set BRANOON SAVITT (1940 ) 09-14-2023 29;
Sct JASON PFEIFFER ( 1920 ) 09-18 - 2023 17:55
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SOM-L-000003-24 01/02/2024 Pg12o0f23 Trans ID: LCV20242787
COURT ID [PREFIX | TICKET NUMBER |SOUTH BOUND BROOK MUNIGIPAL CT
42. MAIN STREET
{& BOUND BROOK, NJ 08880
(732) 988-0258
1819 £23 006970
‘YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THiS COURT TO ANSWER THIS
COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED:
ras Lcensa Nas OSes 2207811882 sued Espinton
Date 1912028 [1] cormerntenta
‘THE UNDERSIGNED GERTIFIES THAT
WeoroRt MoncureLores Da bates aN tt085 “essen: Loaner
SPORE AVE APL A equ bvem vemos ‘apeccor vera? 0
So Male Ratictenen Facaw
SOmERSKT, Na gHIS. 3166 bral addiss:
DID UNLAWFULLY (PARK) (OPERATE) A
Fvavet
Licence Piste No, stash) tutators Yeoct0tt catastier dy Tyna chun vc
portent
G4ONNW cone verses omens COezereus ste [lonersenien
AND DID THEN AND THERE COMMIT THE FOLLOWING OFFENSE
99:450 -»- OPERATING UNDER INFLUENCE OF LIQUOR OR DRUGS
Datoaf Offense: ‘onrter2023 “Tima: 40:69 PIs
cousnsnttel]Constuiznzooo [sats candor [Jesnias2on0
Eelacasent Lrrep.vaaase {_Jacuiy troy [Joeantserons neaiytuny
[Jonas [atest
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Repent Operator: parsers: nteads:
Pos:
Location: Municipality: County: Mun,Codae(Offense}
CANAVIEDGEWOODSOUTH BOUND BROOK TRYMERSET 4
“Tho undersigned further stalas Ural Une ato Jost ond ceasonabte
grounds to hievn that
you contnted the ava olfonsa and wil ais complet In hts cous chszalagyou with tnt offonse,
gp/t812023 OFC C LOWDER 0038
Dale Elocironio Signatwre Officer 1D
YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS GOURT TO ANSWER THIS:
COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED ABOVE,
Court Dale: 09/06/2023
{PLEA OF NOT GUILTY
eT
Gourt Time: 09:30 AM
wd
Ityou wish fo plead not gui, you must nasty the cour, vainso sddvoss and tatephona number ata shown
‘shove, aL asl 6 daya prior 1 Ue court dale bated on ths teat
Ploace confi ufth the courl yaur contact informatton Ineladlng yaur email adios and tolephons
number, ya Filta nobly die eaud, enay ba necessary far youre moka addivonal coud appearances.
2, OFFENSES NOT PAYABLE OR GOURT APPEARANCE REQUIRED
ihe oftense charged tsnot payable, oi "Cour Appaatance Requtes(s lsplayad, you must oppearon die
{date and Ume indicated, vont you wish to plead gutly, Contact tne coutto conbire your appearance, ome
‘advass, and lolaghons eumir,Tho couil may schadule youtTo appear tn person or by ideo. Vou may also
‘ba nba to raselue your maker ontine (sca secon 3 below)
‘S, ONLINE PLEA OPTIONS
Planse visit wow AQdMCalracteor, {ov information on howto rosetve matters antiso wihear aving Io appear
fn court, You maybe abla suboit a reques throuph Ura anne hunkipat Care Resobon system to,
‘emeng other tings, pload gully not guy to Ba offense charged on tas Uczet orto sub mcoquest
toca osser ehergo to Die munkipal proceettor,
COURT APPEARANCE REQUIRED
FOR MORE INFORMATION ON ANY OF THE ABOVE, GOTO:
www.NJMCdirect.com
NoTice
Exeopl tora parking Neko, a recard of hs eorselon witb sealta tha Mister Vhlete Commaslen (MVC)
kot issued your Heanse, yeu Woks cemmercial rived Geena nd you aro convicted af tun of mara
‘Badau9 vali vslaons, tho MG may, dependingan your record, suspcod your commercial eng prilagas
‘ovpi Ifthe violstans wore commlited Ina non-commorelak motor vehicle,
For mara tnexmton, vss he olfelat NVC wetilte ob swine MJHAVE gov,
PLEASE NOWFY IE COURTOF DISABILITY ACCOMODATION REEDS,
os aN
ENSURING
Seasons
JUSTICE ea
SOM-L-000003-24 01/02/2024 Pg130f23 Trans ID: LCV20242787
COURT ID/PREFIX | TICKET NUMBER }SOUTH BOUND BROOK MUNICIPAL CT
42 MAIN STREET
Is BOUND BROOK, NJ 08880
(732) 388-0260
1819 E23 000974
YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS GOURT TO ANSWER THIS
COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED:
Diss ensa th ERASED st) Espraton
Date HOG LL] conmantta
‘THE UNDERSIGNED CERTIFIES THAT
WECTORL MORENTELOPEZ DicpDatest LHS Tebtane: [Jemacestice
SP MORHA AVE APTS Bascom Hegitsase Fopeoortetnnt U
sexu Reatesane Raca¥e
SOMERSET, 11600799165 a1 ASsas5
DID UNLAWFULLY (PARK) (OPERATE) A
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Te
set ep. Dateoaoee
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Toleommersa vein FTJerntnos [CT texantous satsn [llowetsenice
AND DIO THEN AND THERE GONMIT THE FOLLOWING OFFENSE
30:4-50.4A ~-- REFUSAL TO SUBMIT TO CHEMICAL TEST PENALTIES
Batol Ovens: aniter2028 ‘Tao: 10:58 26
onoteare tote] consvein Zane [seo Consn Cerna zene
LEJaceisont Clo. asnnge EJoastratics psatnions
| by iy
Conse Bk]aroet
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ries IF ANO RUN
|
Municipality: Mun. Gada(otfense)
MAINICANAL SOUTH BOUND BROOK THOME RSET
“The undezclgned fer staf0s that are 210 just and reasonabto grounds to baFove thot
{yu commitod th above olfansa and vil fa thle comptaint a ils cout charg you wide thal offense,
08/18/2023 OFC C LOWDER 0038
Date Etectronio Signature Officer 19
YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS COURT TO ANSWER THIS
COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED ABOVE,
Court Date: 09/06/2023 Court Time: 09:30 AM
|avemnnannnnsasnas — aT
4, PLEAOF May GUILTY
youretch to plead nol guity, you must natty the court, hose address ond totephions aumboraf shown
‘oove, #4 Yeas5 days pri lo tha court dala sled on ths eke,
Plesae confirm with the caur your cantacttnfermaion Including your omall address and telephone
svumbor. I youttty to coud, Keayba necossary
for you ta mako addonat oot appearances.
2, OFFENSE 1S HOT PAYABLE OR COURT APPEARANCE REQUIRED
{tha offonso cha:ged tx nol payable, arif*Court Appearance Roqutod" te Usplayed, you aust wapearon tho
sta sod to Idesed, event you wishto pond gy. Contact the cout to confon sour sppeatnce, ent
address, and telephone number, Tha cou say sclieduayou to appa in personor by video, You misyelsa
ba 9b% lo resolve your naleronkina (300 secllan 3 botox),
S,ONLINE PLEA OPTIONS
Plesse viet wwantiMCdlectenm {or tofomation on hax! to eselve mottos online wihounhoviag ie appear
ecu. Vou maybe aba to eubmit a vaquast tough tha one Llaipal Coss Reschiton syste lo,
‘among einer tags, plead gully oF not gosky tothe alense changed om Wns veel or to submil request
tor atesser eherge to tha munlcpatprosecer,
L COURT APPEARANCE REQUIRED
FOR MORE INFORMATION ON ANY OF THE ABOVE, GO TO;
www.NJMCdirect.com
NOTICE
Except fer a paikng Uckot, record ofthe convkilon wit bo sent o te Molar Vehicle Comsston (AVC)
‘that Issued your ¥conco, you held 9 commardla diva’s Feanse ad you oro comet of two oc 10
-sovious vale vaitions, the VC may, dapenting on your raccrd, euspond your chanaerla diving pibiogos
‘ovon If ho violations wore conimilted ina norseomianielal molar vehieto,
os moro tadccmation, vsR tha ofa AVC Webshe al ony ats. pov,
PLEASE NOTIFY THE COURT OF DISABILITY ACCOMODATION NEEDS:
ENSURING
Ss
‘Arercane ith
sopatoNORTD
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SOM-L-000003-24 01/02/2024 Pg 140f23 Trans ID: LCV20242787
COURT ID] PREFIX | TICKET NUMBER |SOUTH ROUND BROOK MUNICIPAL CY
42 MAIN STREET
Is BOUND BROOK, NJ OBBaO
(732) 356-0268
1819 E23 00972
‘YOU ARE HEREY SUMMONED TO APPEAR BEFORE THI8 COURT TO ANSWER THIS
COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED:
— —— —-
vee late Ha MESESROPES surat) Rahn oe wen0st [D1 cormasstucnse
‘THE UNDERSIGNED CERTIFIES THAT
TIRETORL HORETELODEL ‘Sena titinss Yesphener [Lfomsircapims
S2HoRAAveASTAO Byes Breen tegesor ‘Wipatece Uta D
Seethly Heeans0o Rea
20yEnser, I oeensa106 Ems Adtass
‘DID UNLAWBULLY (PARK) (OPERATE)A,
Ukenss Piste No. seuatdatetorerd ‘yee cebvetiven ‘dy Type Php Tuck
Bp. tsteonace
S4ONNW leommerer ates lloras [ftzsraus nats lower senico
AND D1D THEN AND THERE COMMIT THE FOLLOWING OFFENSE
90:4.98A TRAFFIC ON MARKED LANES.NEAREST RIGHT LANE,
Date okoftsnse: obvierz023 “Une: 10:86 PA
onuotevertess[Jomsineten2are Foun codtor []esuoitzore
frcceen Ol rep. Demege (]poaiyigury [_Joeaneserous
nodty aig
Cs avs
epipmece peer openiere tas uncoies
Moss ARO
bee —_
Location: Munielpelity: Coun Mun.Code(Orfense)
MAINICANAL SOUTH BOUND BROOK THOM! RSET
‘Tea undersignes fre slats Ua! Grn are [ust and ceasoatiagrounds lo eka Wat
yeu commited the avovo alfanse ad wil file Us complains
court charglag you wii dat cans,
sarjaize23 OFC CLOWDER 038
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1:PLEA OF NOT QUKIY
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hora, a tench days pe to vo pay by dot ised ca Dis tec
Plosse conflem vAlh tho court your contac informaiton fachudlag your eal address and telephone
‘sumer. iyo fo Yo nai tho co, nay bo ecessary fo You ta ake neon coun appearances,
2. PAYMENTAND GURTY PLEA
‘Yoxtrnay nloxd guilty and pay he panatty \wahout the eacestiy of coun appearence. Gato
wan HUMCdTreel.com lodateastaoittie allensols payable and tha smaunt of Bo Fensiy, You may.
pad guy and pay ie tckel enna Ouargh Ut website, You ray avo plead guy ad eay the penaltyat
fhe court or ou ayaa hs Uke, ogefer ih payee etka enous of ie penaly, ota cout at a
address ndtcated abo, Paynontiaust bo mada pear fo tho pay by data displayed on (ie tcket,
Pegntgts bya aoto Lo made y check or srovey ovdor payed ta this Nenilpal Cour,
Do nat dond cash, Please pat tho Heke nvuniar gn the foWt ef the check or money onder,
A ydyamaalts cecelved by th cour alter Uo pay by dato, you may be assesses eciTona pens.
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you wish to plead guy bat ova web o pay your nas and costs af, go 10 oratiaconeetcoin
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‘2, ONLINE PLEA OPTIONS
Phasavist wunetliNcéirectcem —forlnfonnaton on haw to resdiva matort onto wlireuthasina to appear
Incout Yeu ay be atta fo avbast n request inrough tha ents bturinal Case Rosclaton system,
arora ober ngs, led iy oc ol gully tothe alnvechaged en is eke orto abn areqoes
fora esse charg a prosecute,
Amount of Penalty: $486.00 Pay By Date:09/01/2023
FOR MORE INFORMATION ON ANY OF THE ABOVE, GO TO:
www.NJMCdirect.com
Nouice
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Except fos a padhng Ucet, a rocond of is conkcvon vl bo sen to tie Wolor Vehiclo Gonsnfsfon (AVC)
at sad you eansa, tyou held a gorrmercal vers conse and you cometed of Wo or more sesous
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ven i the violations wore corsmited in a noreconmerclal mater vehicle,
Formate eronmaon vit ho offal RVG yeabs st omy RUMVO. 90%,
PLEASE NOTIFY THE COURT OF DISABILIFY ACCOMODATION NEEDS,
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SOM-L-000003-24 01/02/2024 Pg15o0f23 Trans ID: LCV20242787
COURT {D|PREFIX | TICKET NUMBER |SOUTH BOUND BROOK MUNICIPAL CT
42 MAIN STREET
Is BOUND BROOK, NJ 08880
792) 35660288
1819 E23 000973
YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THI COURT TO ANSWER THIS
COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED:
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1.PLEA GF HoT Guat
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leave conten wilh the court your contact Information Ineluding your onal adress and telephone
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2, PAYTENTANO GUILTY PLEA
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3.ONLINE PLEA OPTIONS
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Amount of Penalty: $186.00 Pay By Dale: 09/01/2023
FOR MORE. INFORMATION ON ANY OF THE ABOVE, GOTO;
www.NJMCdirect.com
NOTICE
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PLEASE NOTIFY THE COURTOF DISABILITY ACCOMODATION NEEDS
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SOM-L-000003-24 01/02/2024 Pg 16o0f23 Trans ID: LCV20242787
COURT ID/PREFIX | TIGKET NUMBER |SOUTH BOUND BROOK MUNICIPAL &T
42. MAIN STREET
Js BOUND BROOK, NJ eoB00
(732) 950-0260
1819 E23 000974
‘YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS COURT TO ANSWER THIS
COMPLAINT GHARGING YOU WITH THE OFFENSE LISTED:
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09/18/2023 OFC ¢ LOWDER 036
Bato Electronic Slanalure Officer 10
YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS COURT TO ANSWER THIS
COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED ABOVE,
Court Date: 09/08/2023 Court Fimo: 09:30 AM
fees SSS SSSA
4, PLEA OF NOT GUILTY
IF you wish to oad not guity, you stu nob tha cour, itosa address and telephone number ara shou
hove a east days ptr to the court data sted nts cen
Please conlira with tha court your contact fnfoamatton Including yaur amalt adios and telephone
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2, OFFENSEtS NOT PAYABLE OR COURT APPEARANCE REQUIRED.
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S.ONLINE PLEA OPTIONS.
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weoud. You maybe abe 1 sebmil a request Brough the one Rluritpal Case Resobion system 1a,
‘money ove tags, plead guy or nok gly to the clfenso charged on is Uckel orto submit a request
for atesger charge tothe eunklpat prosecviot.
COURT APPEARANCE REQUIRED
FOR MORE INFORMATION ON ANY OF THE ABOVE, GO TO:
www.NJMCdirect.com
NOTICE
Excopt or parking Uckat, 2 rocard of Ys camtdlonvill ko certo tho Metae Vehicts Commision (VO)
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Preview
SOM-L-000003-24 01/02/2024 Pglof23 Trans ID: LCV20242787 LAW OFFICES OF STEVEN A. GARNER, LLC 100 Franklin Square Drive Tel; (732) 356-1450 Suite 205 Fax: (732) 356-1451 Somerset, NJ 08873 steven@stevengarnerlaw.com December 22, 2023 Manager, Criminal Division Attn: Motions Clerk Somerset County Courthouse 20 North Bridge Street Somerville, NJ 08876 Re: State of New Jersey v. Hector Morente Lope Motion to Consolidate under Rule 7:8-4 South Bound Brook Municipal Court and Bound Brook Municipal Court Dear Sir/Madam: With regard to the above-referenced matter, please find enclosed an original and one (1) copy of the following: 1 Notice of Motion 2. Certification 3. Proposed Form of Order Kindly return a filed copy of this document to this office in the self-addressed stamped envelope provided for your convenience. Thank you for your attention in this matter. Yours truly, Steven A Garner Steven A. Gamer, Esq. Attorney for Defendant encls. cc: Honorable Kevin Shanahan, J.S.C. SOM-L-000003-24 01/02/2024 Pg2o0f23 Trans ID: LCV20242787 Steven A. Garner, Esq. (#002582003) 100 Franklin Square Drive - Suite 205 Somerset, New Jersey 08873 (732) 356-1450 (tel.) (732) 356-1451 (fax) Attorney for Defendant } SUPERIOR COURT OF NEW JERSEY STATE OF NEW JERSEY, ) SOMERSET COUNTY ) CRIMINAL DIVISION Plaintiff, ) ) SOUTH BOUND BROOK MUNICIPAL COURT VS, ) COMPLAINT.NO.: S-23 2023-0000-14 ) SUMMONS NOS.: E23-000970 to E23-000976 and HECTOR MORENTE LOPEZ, ) BOUND BROOK MUNICIPAL COURT ) SUMMONS NOS.: SC-14445 to SC-14448 Defendant. ) NOTICE OF MOTION FOR ) CONSOLIDATION TO. Honorable Kevin Shanahan, J.S.C. Criminal Division Manager’s Office Assignment Judge Attn: Motions Clerk Somerset County Superior Court Somerset County Courthouse 20 North Bridge Street 20 North Bridge Street Somerville, NJ 08876 Somerville, NJ 08876 Bound Brook Municipal Court Bound Brook Municipal Prosecutor 230 Hamilton Street 230 Hamilton Street Bound Brook, NJ 08805 Bound Brook, NJ 08805 South Bound Brook Municipal Court South Bound Brook Prosecutor 12 Main Street 12 Main Street South Bound Brook, NJ 08880 South Bound Brook, NJ 08880 PLEASE TAKE NOTICE that at a time and date to be set by the Court, that the undersigned, attorney for defendant Hector Morente Lopez, will move before the Somerset County Superior Court, located at 20 North Bridge Street, Somerville, New Jersey, seeking an Order to Consolidate the defendant’s matters in the South Bound Brook Municipal Court (Summons Numbers E23-000970 through E23-000976, along with §23-2023-14 and $23- SOM-L-000003-24 01/02/2024 Pg3o0f23 Trans ID: LCV20242787 2023-17) and the Bound Brook Municipal Court (Summons Numbers SC-14445 to SC- 14448), to be consolidated for trial in the South Bound Brook Municipal Court, as these involve a common question of law or fact arising out of the same facts or circumstances, under Rule 7:8-4, Counsel requests a hearing pursuant to R.3:10 if there is any opposition to this motion. Dated: December 22, 2023 By, Steven A Guracr Steven A. Garner, Esq. Attorney for Defendant, Hector Morente Lopez CERTIFICATION OF SERVICE I hereby certify that this Motion was sent to the above-captioned individuals on this date. Dated: December 22, 2023 By: StevenA Garner Steven A. Garner, Esq. Attorney for Defendant, Hector Morente Lopez SOM-L-000003-24 01/02/2024 Pg4of23 Trans ID: LCV20242787 Steven A. Garner, Esq. (#002582003) 100 Franklin Square Drive — Suite 205 Somerset, New Jersey 08873 (732) 356-1450 (tel.) (732) 356-1451 (fax) Attorney for Defendant ) SUPERIOR COURT OF NEW JERSEY STATE OF NEW JERSEY, ) SOMERSET COUNTY ) CRIMINAL DIVISION Plaintiff, ) ) SOUTH BOUND BROOK MUNICIPAL COURT VS. ) COMPLAINT NO.: 8-23 2023-000014 and 17 ) SUMMONS NOS. :; E23-000970 to E23-000976 and HECTOR MORENTE LOPEZ, ) BOUND BROOK MUNICIPAL COURT ) SUMMONS NOS.: SC-14445 to SC-14448 Defendant. ) ORDER ) This matter having been opened to the Cowt upon motion of Steven A. Garner, Esq., attorney for defendant for an Order for Consolidation, and the Court having considered the annexed letter brief, if any, oral argument, and the rule of law, and for good cause shown, Ttis on this day of » 2024 ORDERED that defendant’s matters in the South Bound Brook Municipal Court (Summons Numbers E23-000970 through E23-000976, along with $23-2023- 14 and $23-2023-17) and the Bound Brook Municipal Court (Summons Numbers SC-14445 to SC-14448) are hereby consolidated for trial in the South Bound Brook Municipal Court, and FURTHER ORDERED that a copy of this Order shall be served upon all Parties within ten (10) days. Dated: JSC. SOM-L-000003-24 01/02/2024 Pg5of23 Trans ID: LCV20242787 Steven A. Garner, Esq. (#002582003) 100 Franklin Square Drive — Suite 205 Somerset, New Jersey 08873 (732) 356-1450 (tel.) (732) 356-1451 (fax) Attorney for Defendant ) SUPERIOR COURT OF NEW JERSEY STATE OF NEW JERSEY, ) SOMERSET COUNTY ) CRIMINAL DIVISION Plaintiff, ) ) SOUTH BOUND BROOK MUNICIPAL COURT vs ) COMPLAINT NO.: 8-23 2023-0000-14 ) SUMMONS NOS.: E23-000970 to E23-000976 and HECTOR MORENTE LOPEZ, ) BOUND BROOK MUNICIPAL COURT ) SUMMONS NOS.: SC-14445 to SC-14448 Defendant. } CERTIFICATION FOR MOTION ) FOR CONSOLIDATION I, STEVEN A, GARNER, ESQ., of full age, hereby certify as follows: 1 1 am the attorney for the Defendant in the above-captioned matter, am fully familiar with the facts of this case and am authorized to make this Certification, 2. On August 18, 2023, the Defendant, Hector Morente Lopez, was charged with various motor vehicle violations while traveling through the adjacent towns of South Bound Brook, New Jersey and Bound Brook, New Jersey, with both towns being located in Somerset County. 3 The South Bound Brook Police Incident Report (#23234292) indicates that the officer involved was “traveling North on South Main Street in Bound Brook Borough” when his “patrol unit was struck by a silver pickup truck that had crossed into the Northbound Lane of travel as it was traveling South.” The officer “maneuvered his vehicle around and caught up to the silver pickup truck which was a Ford F-150, silver in color, bearing NI registration, GA(ONNW and activated his lights and siren.” The officer SOM-L-000003-24 01/02/2024 Pg6of23 Trans ID: LCV20242787 had pursued the vehicle “North over the Queens Bridge” and after some time “the vehicle stops at the red light.” A DWI investigation began afier that. (Please see the incident report for the officer’s further details.) 4 The South Bound Brook Police Department later issued tickets to the Defendant with Summons Numbers E23-000970 through E23-000976, along with S23- 2023-14 (SBB Borough Ordinance 3-9.6 Interfering with Borough Officials) and $23- 2023-17 (SBB Borough Ordinance 3-9.8 Fleeing from Police Officer). (Please see Summonses provided.) 5 The Bound Brook Police Department later issued tickets to the Defendant with Summons Numbers SC-14445 to SC-14448. (Please see Summonses provided.) 6 Under Rule 7:8-4, “The court may order two or more complaints to be tried together if the offenses arose out of the same facts and circumstances, regardless of the number of defendants. In all other matters, the court may consolidate complaints for trial with the consent of the persons charged. A party seeking consolidation Complaints originating in two or more municipalities may be consolidated for trial only with the approval of the appropriate Assignment Judge, who shall designate the municipal court in which trial is to proceed. A party seeking consolidation of complaints originating in different municipalities shall file a written motion for that relief directly with the Assignment Judge.” 7. These two matters in South Bound Brook and Bound Brook involve the ame facts and circumstances in that these incidents were all part of one continuous motor vehicle operation on the same date one after the other. The driver was not shown to have left or stopped his vehicle in between these incidents. It was really one continuous offense that took part through two separate towns via connecting roads. 8 These should all be heard in one court, namely the South Bound Brook SOM-L-000003-24 01/02/2024 Pg7of23 Trans ID: LCV20242787 Municipal Court, for judicial economy of the Courts’ time and resources rather than the same facts and circumstances in two separate courts for similar charges. This also should be heard in one court in fairness to the Defendant who committed one act or series of acts, but through two independent towns. The Defendant and the Court should have an opportunity to arrive at a global resolution of all charges knowing all the facts and circumstances of this incident at one time. The Prosecutor in Bound Brook Municipal Court has consented to this and it is the same Judge, namely the Honorable Michael Fedun, J.M.C., who sits in both Municipal Courts. As such, we are asking that these matters be consolidated with both matters heard at the same time. I certify that the foregoing statements made by me are true. | am aware that if any of the statements made by me are willfully false, 1 am subject to punishment. Dated: 12/22/2023 By: Stoven Ah Garner Steven A. Garner, Esq. Attorney for Defendant, Hector Morente Lopez. SOM-L-000003-24 01/02/2024 Pg 8of23 Trans ID: LCV20242787 e SOUTH BOUND BROOK POLICE SOUTH BOUND BROOK, NJ Incident # 23234292 Summary felitecimacs INCIDENT APP I ae 104 On 08/18/2023 at approximately 22:00 hours while waveling Noxth on South Main Street in Bound Brook Borough in the area of 50 S. Main Street, my patrol unit was struck by a silver pickup truck that had crossed into the Northbound Lane of travel as it was traveling South, Note: ‘This Officer was about to initiate a motor vehicle stop and my dashcam had already been activated capturing the motor vehicle collision with sound, Please refer to Bound Brook PD accident report case 23013072, As I looked in my mirror immediately after the collision, I observed the silver pickup truck continuing South as it passed two parking lots 50 S. Main Street and 69 S. Main Street. I maneuvered my vehicle around and began driving [North over the Queens Bridge to catoh up with the silver pickup truck, at this time my overhead lights were activated. In the area of Main Street and Canal Rd, 1 observed the same pickup truck which was a Ford F-150, silver in color, beating NJ registration, G4ONNW and activated my lights and siren. The defendant's vehicle turned right fiom the Queens Bridge onto Canal Road, As the vehicle made the wide right-hand turn it entered into the Eastbound Lane of travel and continued West down Canal Road. As the vehicle was traveling West on Canal it continued West in the Eastbound Lane for approximately one block from Canal Rd. and Main St, to Elizabeth and Canal Road as the vehicle straddled the double yellow line, The suspect vehicle also had his left turn signal on and never turned feft onto Elizabeth Street, While the vehicle continued West I was communicating with dispatch notifying them the vehicle was failing to stop traveling at a safe speed, Notifying dispatch of my speed as I followed the vehicle and of my current location the vehicle continued to not stop. In the area of Canal Rd. and Van Sickle Blvd, the vehicle traveled over the center fine. In the area of Canal Rd. and Equator Ave., the vehicle crossed over the white fog line. In the area of Canal Rd. and Jerome Ave. the vehicle orossed over the white line and xemains driving over the white line for approximately one block until it reaches the area of Canal Rd. and Howard Ave. where the rear passenger side tire touches the dirt and grass leaving the roadway. In the area of Canal Rd. and Sanders Ave, the vehicle crosses over the white line and uses its left turn signal again however, continues straight, In the area of Weston Canal Rd, and Route 287 the vehicle stops at the red light. As I exit my marked patrol unit, | observed the defendant later identified as Hector L. Morente-Lopez, swaying his head and yelling “what , what, what” as I ordered him out of the vehicle. I opened the defendant’s vehicle and I could immediately detect the odor of an alcoholic beverage emitting fiom the defendant. I also observed the defendant’s eyes were watery and bloodshot red. I guided the defendaut out of the vehicle at which time he fell due to poor balance, I placed the defendant in handcuffs at this time for safety. Page #2 SOM-L-000003-24 01/02/2024 Pg9of23 Trans ID: LCV20242787 SOUTH BOUND BROOK POLICE SOUTH BOUND BROOK, NJ Incident # 23234292 Summary iter Tee Around this time, Ofc. Kieslor, Ofc. Rodriguez Bound Brook PD, Ofc. Sabal BBPD, Sgt. Wertheim BBPD arrived on scene, as backup. Of. Kieslor contacted Sgt. Savitt who later responded to the scene as he was at headquarters as his shift had just ended. Two Frankdin Twp. Officers also responded to the scene. While on scene Ofc. Rodriguez was advised of the sequence of events for the accident report and later provided ail Necessary documents to complete the accident report. Artest Decision: Based on the following information, I formed the opinion the defendant was under the influence. The defendant operating the yehiele that suck my marked patrol unit and fled the scene, The defendant failing to stop for this officer whose emergency lights and sirens were activated for an extended period of time. The defendant failing to turn/improperly using his turn signal multiple times. The defendant’s bloodshot watery eyes, and the strong odor of an alcoholic beverage emitting from the defendant and Iris breath. The defendants erratic driving behavior, the defendant failing to maintain his lane repeatedly. T arrested the defendant for suspicion of DWI. The defendant was searched incident to arrest and placed in the rear of my patrol vehicle. Somerset Hills Towing responded to tow the vehicle. While at HQ: The defendant was removed from the rear of the police vehicle. There was the smell of ati alcoholic beverage coming from the rear of the patrol vehicle that was not there prior to placing the defendant there, The defendant was brought inside police headquarters to the booking area where he was again searched and secured to the booking bench. The defendant was read the NJ Attorney General's Standard Statement for DWI by Ofc. Rodriguez in Spanish. The defendant replied, "No" to providing breath samples. A 20-minute observation period was still conducted and the defendant was issued the refusal for refusing to provide breath samples. During that time the defendant did not Page #3 SOM-L-000003-24 01/02/2024 Pg10o0f23 Trans ID: LCV20242787 SOUTH BOUND BROOK POLICE SOUTH BOUND BROOK, NJ Incident # 23234292 Summary Oiler lere)} ingest, regurgitate, or placed anything inside of his mouth. Sgt. Savitt administered the Alcotest for the refusal, Upon completion of the Alcotest, the defendant was read the Miranda form in English which he relayed he understood, The defendant later refused to sign the Miranda form and when questioned on the drinking questionnaire form, he relayed his “lawyer will take care of this”. The defendant’s brother Marvin Morente-Lopez was contacted and responded to headquarters where he signed a Potential Liability Warning form, Marvin was given a copy of the paperwork, The defendant was then released under the care of his brother, Note: The defendant would continue to say le understood English than that he did not, Sgt. Savitt, Ofc. Kieslor, and Ofc, Rodviguez were all al HQ during this time. Sgt. Savitt notified Lt. LaGrua of this incident. Motor Vehicle Violations and Borough Ordinances Issued: £23000970 39:4-50 DWI 823000971 39:4-50,.4A Refusal 23000972 39:4-88A Traffic marked lanes nearest right E23000973 39:4-88C Traffic marked lanes center lane violation 23000974 39:4-96 Reckless Driving 23000975 39:4-97 Careless Driving E23000976 39:4-9{ Failure To Yield Right Of Way To Emergency Vehicles Page #4 SOM-L-000003-24 01/02/2024 Pg1lof23 Trans ID: LCV20242787 SOUTH BOUND BROOK POLICE SOUTH BOUND BROOK, NJ Incident # 23234292 Summary fei inicio) * $232023000014 SBB B.O, 3-9.6 Interfering with Borough Officials + §232023000017 SBB B.O. 3-9.8 Fleeing from Police Officer (Mailed on 08/20/2023). The following complaints for title 39 violations were signed with the Bound Brook Borough Municipal Court on 08/24/2023 at approximately 13:45 hours. All tickets were later mailed to the defendant. 18044076576 39:4-97 Careless Driving 18044076577 88.B Failure to keep right 1804A076578 130 Failure to report an accident 18044076579 39:4-[29 Leaving the scene of an accident The defendant was provided all copies and mailed B.O, #8232023000017, ATS/ACS/NCIC all checked, negative results, ce} ect PLC) REPORTING OFFICER: DATE/TIME ENTERED ore IRO LOWDER (1946 ) -18-: Ri set BRANOON SAVITT (1940 ) 09-14-2023 29; Sct JASON PFEIFFER ( 1920 ) 09-18 - 2023 17:55 Page #5 SOM-L-000003-24 01/02/2024 Pg12o0f23 Trans ID: LCV20242787 COURT ID [PREFIX | TICKET NUMBER |SOUTH BOUND BROOK MUNIGIPAL CT 42. MAIN STREET {& BOUND BROOK, NJ 08880 (732) 988-0258 1819 £23 006970 ‘YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THiS COURT TO ANSWER THIS COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED: ras Lcensa Nas OSes 2207811882 sued Espinton Date 1912028 [1] cormerntenta ‘THE UNDERSIGNED GERTIFIES THAT WeoroRt MoncureLores Da bates aN tt085 “essen: Loaner SPORE AVE APL A equ bvem vemos ‘apeccor vera? 0 So Male Ratictenen Facaw SOmERSKT, Na gHIS. 3166 bral addiss: DID UNLAWFULLY (PARK) (OPERATE) A Fvavet Licence Piste No, stash) tutators Yeoct0tt catastier dy Tyna chun vc portent G4ONNW cone verses omens COezereus ste [lonersenien AND DID THEN AND THERE COMMIT THE FOLLOWING OFFENSE 99:450 -»- OPERATING UNDER INFLUENCE OF LIQUOR OR DRUGS Datoaf Offense: ‘onrter2023 “Tima: 40:69 PIs cousnsnttel]Constuiznzooo [sats candor [Jesnias2on0 Eelacasent Lrrep.vaaase {_Jacuiy troy [Joeantserons neaiytuny [Jonas [atest asses eT Repent Operator: parsers: nteads: Pos: Location: Municipality: County: Mun,Codae(Offense} CANAVIEDGEWOODSOUTH BOUND BROOK TRYMERSET 4 “Tho undersigned further stalas Ural Une ato Jost ond ceasonabte grounds to hievn that you contnted the ava olfonsa and wil ais complet In hts cous chszalagyou with tnt offonse, gp/t812023 OFC C LOWDER 0038 Dale Elocironio Signatwre Officer 1D YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS GOURT TO ANSWER THIS: COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED ABOVE, Court Dale: 09/06/2023 {PLEA OF NOT GUILTY eT Gourt Time: 09:30 AM wd Ityou wish fo plead not gui, you must nasty the cour, vainso sddvoss and tatephona number ata shown ‘shove, aL asl 6 daya prior 1 Ue court dale bated on ths teat Ploace confi ufth the courl yaur contact informatton Ineladlng yaur email adios and tolephons number, ya Filta nobly die eaud, enay ba necessary far youre moka addivonal coud appearances. 2, OFFENSES NOT PAYABLE OR GOURT APPEARANCE REQUIRED ihe oftense charged tsnot payable, oi "Cour Appaatance Requtes(s lsplayad, you must oppearon die {date and Ume indicated, vont you wish to plead gutly, Contact tne coutto conbire your appearance, ome ‘advass, and lolaghons eumir,Tho couil may schadule youtTo appear tn person or by ideo. Vou may also ‘ba nba to raselue your maker ontine (sca secon 3 below) ‘S, ONLINE PLEA OPTIONS Planse visit wow AQdMCalracteor, {ov information on howto rosetve matters antiso wihear aving Io appear fn court, You maybe abla suboit a reques throuph Ura anne hunkipat Care Resobon system to, ‘emeng other tings, pload gully not guy to Ba offense charged on tas Uczet orto sub mcoquest toca osser ehergo to Die munkipal proceettor, COURT APPEARANCE REQUIRED FOR MORE INFORMATION ON ANY OF THE ABOVE, GOTO: www.NJMCdirect.com NoTice Exeopl tora parking Neko, a recard of hs eorselon witb sealta tha Mister Vhlete Commaslen (MVC) kot issued your Heanse, yeu Woks cemmercial rived Geena nd you aro convicted af tun of mara ‘Badau9 vali vslaons, tho MG may, dependingan your record, suspcod your commercial eng prilagas ‘ovpi Ifthe violstans wore commlited Ina non-commorelak motor vehicle, For mara tnexmton, vss he olfelat NVC wetilte ob swine MJHAVE gov, PLEASE NOWFY IE COURTOF DISABILITY ACCOMODATION REEDS, os aN ENSURING Seasons JUSTICE ea SOM-L-000003-24 01/02/2024 Pg130f23 Trans ID: LCV20242787 COURT ID/PREFIX | TICKET NUMBER }SOUTH BOUND BROOK MUNICIPAL CT 42 MAIN STREET Is BOUND BROOK, NJ 08880 (732) 388-0260 1819 E23 000974 YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS GOURT TO ANSWER THIS COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED: Diss ensa th ERASED st) Espraton Date HOG LL] conmantta ‘THE UNDERSIGNED CERTIFIES THAT WECTORL MORENTELOPEZ DicpDatest LHS Tebtane: [Jemacestice SP MORHA AVE APTS Bascom Hegitsase Fopeoortetnnt U sexu Reatesane Raca¥e SOMERSET, 11600799165 a1 ASsas5 DID UNLAWFULLY (PARK) (OPERATE) A Heenso Plato tla, bssterond Yeon7001 aoe. Body Bparickup Te set ep. Dateoaoee G40NNW Toleommersa vein FTJerntnos [CT texantous satsn [llowetsenice AND DIO THEN AND THERE GONMIT THE FOLLOWING OFFENSE 30:4-50.4A ~-- REFUSAL TO SUBMIT TO CHEMICAL TEST PENALTIES Batol Ovens: aniter2028 ‘Tao: 10:58 26 onoteare tote] consvein Zane [seo Consn Cerna zene LEJaceisont Clo. asnnge EJoastratics psatnions | by iy Conse Bk]aroet _ Favmaat Cosco Openingstt:35 wercades ries IF ANO RUN | Municipality: Mun. Gada(otfense) MAINICANAL SOUTH BOUND BROOK THOME RSET “The undezclgned fer staf0s that are 210 just and reasonabto grounds to baFove thot {yu commitod th above olfansa and vil fa thle comptaint a ils cout charg you wide thal offense, 08/18/2023 OFC C LOWDER 0038 Date Etectronio Signature Officer 19 YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS COURT TO ANSWER THIS COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED ABOVE, Court Date: 09/06/2023 Court Time: 09:30 AM |avemnnannnnsasnas — aT 4, PLEAOF May GUILTY youretch to plead nol guity, you must natty the court, hose address ond totephions aumboraf shown ‘oove, #4 Yeas5 days pri lo tha court dala sled on ths eke, Plesae confirm with the caur your cantacttnfermaion Including your omall address and telephone svumbor. I youttty to coud, Keayba necossary for you ta mako addonat oot appearances. 2, OFFENSE 1S HOT PAYABLE OR COURT APPEARANCE REQUIRED {tha offonso cha:ged tx nol payable, arif*Court Appearance Roqutod" te Usplayed, you aust wapearon tho sta sod to Idesed, event you wishto pond gy. Contact the cout to confon sour sppeatnce, ent address, and telephone number, Tha cou say sclieduayou to appa in personor by video, You misyelsa ba 9b% lo resolve your naleronkina (300 secllan 3 botox), S,ONLINE PLEA OPTIONS Plesse viet wwantiMCdlectenm {or tofomation on hax! to eselve mottos online wihounhoviag ie appear ecu. Vou maybe aba to eubmit a vaquast tough tha one Llaipal Coss Reschiton syste lo, ‘among einer tags, plead gully oF not gosky tothe alense changed om Wns veel or to submil request tor atesser eherge to tha munlcpatprosecer, L COURT APPEARANCE REQUIRED FOR MORE INFORMATION ON ANY OF THE ABOVE, GO TO; www.NJMCdirect.com NOTICE Except fer a paikng Uckot, record ofthe convkilon wit bo sent o te Molar Vehicle Comsston (AVC) ‘that Issued your ¥conco, you held 9 commardla diva’s Feanse ad you oro comet of two oc 10 -sovious vale vaitions, the VC may, dapenting on your raccrd, euspond your chanaerla diving pibiogos ‘ovon If ho violations wore conimilted ina norseomianielal molar vehieto, os moro tadccmation, vsR tha ofa AVC Webshe al ony ats. pov, PLEASE NOTIFY THE COURT OF DISABILITY ACCOMODATION NEEDS: ENSURING Ss ‘Arercane ith sopatoNORTD I I ea SOM-L-000003-24 01/02/2024 Pg 140f23 Trans ID: LCV20242787 COURT ID] PREFIX | TICKET NUMBER |SOUTH ROUND BROOK MUNICIPAL CY 42 MAIN STREET Is BOUND BROOK, NJ OBBaO (732) 356-0268 1819 E23 00972 ‘YOU ARE HEREY SUMMONED TO APPEAR BEFORE THI8 COURT TO ANSWER THIS COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED: — —— —- vee late Ha MESESROPES surat) Rahn oe wen0st [D1 cormasstucnse ‘THE UNDERSIGNED CERTIFIES THAT TIRETORL HORETELODEL ‘Sena titinss Yesphener [Lfomsircapims S2HoRAAveASTAO Byes Breen tegesor ‘Wipatece Uta D Seethly Heeans0o Rea 20yEnser, I oeensa106 Ems Adtass ‘DID UNLAWBULLY (PARK) (OPERATE)A, Ukenss Piste No. seuatdatetorerd ‘yee cebvetiven ‘dy Type Php Tuck Bp. tsteonace S4ONNW leommerer ates lloras [ftzsraus nats lower senico AND D1D THEN AND THERE COMMIT THE FOLLOWING OFFENSE 90:4.98A TRAFFIC ON MARKED LANES.NEAREST RIGHT LANE, Date okoftsnse: obvierz023 “Une: 10:86 PA onuotevertess[Jomsineten2are Foun codtor []esuoitzore frcceen Ol rep. Demege (]poaiyigury [_Joeaneserous nodty aig Cs avs epipmece peer openiere tas uncoies Moss ARO bee —_ Location: Munielpelity: Coun Mun.Code(Orfense) MAINICANAL SOUTH BOUND BROOK THOM! RSET ‘Tea undersignes fre slats Ua! Grn are [ust and ceasoatiagrounds lo eka Wat yeu commited the avovo alfanse ad wil file Us complains court charglag you wii dat cans, sarjaize23 OFC CLOWDER 038 Bate Eteovonie Signature ‘offeer 1D 1:PLEA OF NOT QUKIY yowsisetoptead nol exit, you msl nelly tho coun, whase aires ons telephone cener ava shan hora, a tench days pe to vo pay by dot ised ca Dis tec Plosse conflem vAlh tho court your contac informaiton fachudlag your eal address and telephone ‘sumer. iyo fo Yo nai tho co, nay bo ecessary fo You ta ake neon coun appearances, 2. PAYMENTAND GURTY PLEA ‘Yoxtrnay nloxd guilty and pay he panatty \wahout the eacestiy of coun appearence. Gato wan HUMCdTreel.com lodateastaoittie allensols payable and tha smaunt of Bo Fensiy, You may. pad guy and pay ie tckel enna Ouargh Ut website, You ray avo plead guy ad eay the penaltyat fhe court or ou ayaa hs Uke, ogefer ih payee etka enous of ie penaly, ota cout at a address ndtcated abo, Paynontiaust bo mada pear fo tho pay by data displayed on (ie tcket, Pegntgts bya aoto Lo made y check or srovey ovdor payed ta this Nenilpal Cour, Do nat dond cash, Please pat tho Heke nvuniar gn the foWt ef the check or money onder, A ydyamaalts cecelved by th cour alter Uo pay by dato, you may be assesses eciTona pens. ‘Aceceph tle senttayou ‘any I yoor paymentts accompanied bya gelCodiressed, slamped east, you wish to plead guy bat ova web o pay your nas and costs af, go 10 oratiaconeetcoin ‘oc ensjael Ue cout or meee lalansaton. ‘2, ONLINE PLEA OPTIONS Phasavist wunetliNcéirectcem —forlnfonnaton on haw to resdiva matort onto wlireuthasina to appear Incout Yeu ay be atta fo avbast n request inrough tha ents bturinal Case Rosclaton system, arora ober ngs, led iy oc ol gully tothe alnvechaged en is eke orto abn areqoes fora esse charg a prosecute, Amount of Penalty: $486.00 Pay By Date:09/01/2023 FOR MORE INFORMATION ON ANY OF THE ABOVE, GO TO: www.NJMCdirect.com Nouice — — pecnaneamr Except fos a padhng Ucet, a rocond of is conkcvon vl bo sen to tie Wolor Vehiclo Gonsnfsfon (AVC) at sad you eansa, tyou held a gorrmercal vers conse and you cometed of Wo or more sesous ‘Valle olatons, tua SVC may, depending on you sedrd, suspend your commer dking piges ven i the violations wore corsmited in a noreconmerclal mater vehicle, Formate eronmaon vit ho offal RVG yeabs st omy RUMVO. 90%, PLEASE NOTIFY THE COURT OF DISABILIFY ACCOMODATION NEEDS, ea ¥ . AD ea ARSON SOM-L-000003-24 01/02/2024 Pg15o0f23 Trans ID: LCV20242787 COURT {D|PREFIX | TICKET NUMBER |SOUTH BOUND BROOK MUNICIPAL CT 42 MAIN STREET Is BOUND BROOK, NJ 08880 792) 35660288 1819 E23 000973 YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THI COURT TO ANSWER THIS COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED: jo —_— _ ers can Was 15 a6 aR07S 00682 ou Gopafon Oa THORNE EE creniratteese THE UNDERSIGNED CERTIFES THAT Mecron\ NoReWeLoPEZ, Oho oaAtHOAS Tesora: Ll omnceine AHORA AYE AST Eyeriraun, swpnesese Wipuieectatad U So Ualy Resticreens00 naew SOUERSET NJ 4733166 sosinatnss: DID UNLAWFULLY (PARK) (GPERATE) A ‘conse Plats No, sorelvordabororers Yeart0 casestner aly Tp PleayeFrock Sp.dateneneat G40NNW ET Jeoreorta vane Eoreenes teens ners [onersenics ANO O10 THEN AND THERE COMMIT THE FOLLOWING OFFENSE — 3014-88 —- TRAFFIC ON MARKED LANES - CENTER LANE VIOLATION Dota ofottense: oasiai2023 Time: 40:56 P25 cxvorvionsn Jeomvetintara sat contor [osu zou Trceven Cpr, Demeg [Joasty itoy [TJoeanseious necty pny [pws Pecos punts tas Vat Cada Nas AND RU sl Location: Muntctpeliy: Count : Mun.CodetOffense) MAINIGANAL SOUTH BOUND BROOK Tea RSET mt ‘Tha understgted farther slates Uist there oto fus ond reesonsh grounds lo beteve tat $0 conti teste oes and vo Us eomplat ns aut charglog youth nfs, oafiniz023 OFC CLOWOER 0038 Date Blectonte Signature Officer 10 0 1.PLEA GF HoT Guat ‘Hyouwish lo plead nel guty, you must nob thy covet, whose addsous and ilaphona number azo shown ova, el te951 5S days pir totho pay by data Fstodon Os kon. leave conten wilh the court your contact Information Ineluding your onal adress and telephone tuner, Hy alto noi Ure cour, may be necessory for you to nak alana coun appeatences, 2, PAYTENTANO GUILTY PLEA Youmsay plead qulty and pay the panally shout te necessity of cout appearance, Goto wwoealuticaract coat fodstemnsaitihe cliansols payable onde ancunt ofthe poaaiy. You may lees quity on py tis ket ante Evough thal websto. Yeu may ese plead quity and paythe penahy at {a cout or ys may’ malt hs deel, togather wh payment he artount a te pansy toe cout al the address nected above, Paynaent ett ba miada puter ta to pey hy date alaplayed on thi tlekal, ayaneos ty matt aro be mado by check oF money order 93ysbHat hs Muriel Cot, Oo not aon ath, Pleat iat tho ekot numberon tho front of the shack or mnoney ardar, {payments cecelvod ty th sour afar te poy by date, you may be assessed adcMarat penallas. Arocelplwilua centtoyoy only Hour payment fs occonpanled by a seladdeessed, stamped envelop, yoo wih io glead getty bul ore alfa pay your nes and costs afl. 9019 ‘wutsMcéieectcom oreantact to court far mora tformaton, 3.ONLINE PLEA OPTIONS Plessavish yrummstsncdleect.com fer ltormaten on ter to cosohio inaiers ents witout having eppear ‘cout. Vou ray bo abe to sub 9 quest cugh he ovinn Hloneipal Gase Resebicasyatrn lo, seve obra Wings, eet gully oral ety lose olense cagtd on is Uckelcrta svbn8 a reques) ar atasser nig totus auntelpa geosteutes el Amount of Penalty: $186.00 Pay By Dale: 09/01/2023 FOR MORE. INFORMATION ON ANY OF THE ABOVE, GOTO; www.NJMCdirect.com NOTICE Facontlora pading ikke,» raca%d of tite comictton le een othe Matos Vebicte Commission MVC) (at stusd your causa. t you hold a commetl| diver’ Feensa baé you conttled of 40.6¢ or8 seas ‘ahs ipsam, the AAO may, UEpendg on YOU! Ceco, uapend your CeMmeiC akg IMS ‘oven ii the letatlons Wore comunttedI anien-conmézclal motor ede, Foc sorotaforman, vs the offal AVC wabsto at ‘yn RINE. go, PLEASE NOTIFY THE COURTOF DISABILITY ACCOMODATION NEEDS ENSURING fro ‘SnD i ea SOM-L-000003-24 01/02/2024 Pg 16o0f23 Trans ID: LCV20242787 COURT ID/PREFIX | TIGKET NUMBER |SOUTH BOUND BROOK MUNICIPAL &T 42. MAIN STREET Js BOUND BROOK, NJ eoB00 (732) 950-0260 1819 E23 000974 ‘YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS COURT TO ANSWER THIS COMPLAINT GHARGING YOU WITH THE OFFENSE LISTED: nfs cea a: Mes483207360852 sol Eipiaten date NE (11 conc tiene S2HORMAABAPLIO. yee COHN Hepes Hpanoer Laine? Soe Pala Reswcionca roe SONENBET,H3.08879-9108 EmstAaivor _ DID UNLAWFULLY (PARIG (OPERATE) A Uceaso Plata tte, suis ost lava Matar ‘Yeor201 ep tose ote Gavsesier Body Typs:Piup True G4ONNW TL Jeonmerctsr vets (Clonnitus [}Hozaus inten lester senden AND O10 THEN AND THERE COMMIT THE FOLLOWING OFFENSE 20:4-86 ~ RECKLESS DRIVING Date of Ofonses gartarz023 Tio: 10:56 Pat enw ctiatimcn|“Jeantvetinzor» Leto contor Jesuit zona HEpccnen Cerp.oemsge [Taoesy tury [Josstuserious Body njory F]oaee [EJakeiot apron penne, Oysters 0:38 sicedea tees AO RUM Location: Muntelpaltty: County: Mun,CodoOffense) MAINICANAL SOUTH BOUND BROOK TSOMERSET 4819 ‘Tue undeclgnes funher stale that tera ata fast and reasonuble grunts (0 eltovs that ost comantiedto above conse and wit a is comptelat in tis court charging you thal otfonse, 09/18/2023 OFC ¢ LOWDER 036 Bato Electronic Slanalure Officer 10 YOU ARE HEREBY SUMMONED TO APPEAR BEFORE THIS COURT TO ANSWER THIS COMPLAINT CHARGING YOU WITH THE OFFENSE LISTED ABOVE, Court Date: 09/08/2023 Court Fimo: 09:30 AM fees SSS SSSA 4, PLEA OF NOT GUILTY IF you wish to oad not guity, you stu nob tha cour, itosa address and telephone number ara shou hove a east days ptr to the court data sted nts cen Please conlira with tha court your contact fnfoamatton Including yaur amalt adios and telephone dnuvor (yeu (ato catiy tho cove, tmay bo Wecoessry fer you to make sddvondl cauit appamsonces, 2, OFFENSEtS NOT PAYABLE OR COURT APPEARANCE REQUIRED. tune alfense charged te nol payatle of “Cou Appearance Required ts dsplyed, you msl oppear op the dato and Ymo trdicaled even you wish fo plead gully, Conlact tha cout to confine your eppearance, omalh dévass, and ofgahono numer,Tho cour may schodule you lo ap0ar ns parson or by video. You may also ‘va abtCo sasolve your malar ontne (sao section 3 below), S.ONLINE PLEA OPTIONS. Pease vist waautaMCalract.com for tompattonen howto cesoive mai online vidhout having to epzear weoud. You maybe abe 1 sebmil a request Brough the one Rluritpal Case Resobion system 1a, ‘money ove tags, plead guy or nok gly to the clfenso charged on is Uckel orto submit a request for atesger charge tothe eunklpat prosecviot. COURT APPEARANCE REQUIRED FOR MORE INFORMATION ON ANY OF THE ABOVE, GO TO: www.NJMCdirect.com NOTICE Excopt or parking Uckat, 2 rocard of Ys camtdlonvill ko certo tho Metae Vehicts Commision (VO) ‘hot{ssued your icenso, M you