UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

DR. MAX DENIS ANTOINE, PRO SE LITIGANT

P.O. BOX 3393

JERSEY CITY, NEW JERSEY 07303

ACSGLOBALMAX@YAHOO.COM

TEL. (202) 000-0000 ENCRYPTED

WWW.JUSTICEFORMAX.COM

___________________________________________

DR. MAX D. ANTOINE, (FATHER)

NELCHAEL S. ANTOINE (MINOR),

MAXINE B. ANTOINE (MINOR),

SATAEL D. ANTOINE (MINOR)

Plaintiffs,

-Against-

BELLEVILLE MUNICIPAL COURT,                      FEDERAL CIVIL ACTION

TOWNSHIP OF BELLEVILLE,

ESSEX COUNTY CORRECTIONAL JAIL,           DOCKET NO.: 10-CV-1212 KSH

JOHN DOES (1 TO 12),

JANE DOES (1 TO 12),

Defendants,

___________________________________________

“CIVIL RIGHTS COMPLAINT AND JURY DEMAND”

“JUSTICE DELAY IS JUSTICE DENIED “

($7,777,777.00 MILLION)

PRELIMINARY STATEMENT

1. This is a civil rights action in which the plaintiffs, Dr. Max Denis Antoine, his princess daughter Nelchael Antoine, his beloved unique son Satael Antoine, and his angelic daughter Maxine Antoine, seek relief and punitive damage for the defendants’ violation of their rights secured by 42 U.S.C. 1964, 1970, 1981,1983,1985 and 1988,by the Constitution, including its First, Fourth, Fifth, and Fourteenth amendments, the Federal Rico Act as amended, the ADA (American with Disability Act), and by the laws and Constitution of the State of New Jersey Laws Against Discrimination (the LAD laws).

1. The Plaintiff seeks damages, both compensatory and punitive, affirmative and equitable relief, an award of costs and attorney’s fees, and such other further relief and punitive injunctions as this Court deems equitable and just.

JURISDICTION & VENUE

1. This action is brought pursuant to 42.U.S.C 1964, 1970, 1981, 1983, 1985 and 1988, and the Constitution of the United States including its First, the Fifth, Fourth and Fourteenth Amendments.

Jurisdiction is conferred upon this Court By U.S.C 1964, 1981, 1983, 1985 and 1988, the Federal Rico Act, the New Jersey Laws Against Targeted Discrimination and 28 U.S.C. 1331 AND 1343 (3) and (4), and the Federal ADA law. This being an action seeking immediate and undisputable redress for the violation of plaintiffs’ State and Federal Constitutional and Civil rights. The Organized Crime Control Act 0f 1970, RICO Act, 18 U.S.C. 1961-68 (1994), Section 1961 & 1962 (c), the C.D.A. Act, 47 U.S.C. 230 et Seq, the American Disability Act (ADA).

1. The Plaintiffs further invoke this Court’s supplemental jurisdiction, pursuant to 28 U.S.C. 1367, over any and all State law claims and as against all parties that are so related to these claims in this action with the original jurisdiction of this Court that they form part of the same case or controversy. DirecTv  v. Rosenberg, 2004 WL 345 523 (S.D.N.Y.), Conspiracy to inflict injury, Conspiracy to Fabricate and Use a False Expunged Negative Warrant, Racketeering with other Agencies to Proximate a False Arrest and Detention, Libelous defamation of Reputation, Trade libel and slander, Unfair Competition affecting the Plaintiffs’ Employment, Business Boycotting of the Plaintiffs by the Said Fake Expunged Negative Warrant, State law violation of Expungement Records, and violation of the Federal Privacy Act of the Plaintiffs on April 08, 2009.

1. The Plaintiffs demand a trial by a mixed Jury on each and every one of their factual claims as pleaded herein.

1. Venue is proper for the United States District Court for the District of New Jersey Pursuant to 28 U.S.C 1391.

1. Plaintiff Dr. Max Antoine is and was all times relevant herein a Citizen of the United States, a resident of the State of New Jersey and of African descent and Haitian heritage. He is of course the glorious father of the following aforesaid three children.

1. Plaintiff NELCHAEL ANTOINE is a Born Citizen of the United States, born July 10, 1994 and is a resident of the state of New Jersey, and is also of African descent and Haitian heritage.

1. Plaintiff MAXINE ANTOINE is a Born Citizen of the United States, born October 25, 1997 and is a resident of the state of New Jersey, and is also of African descent and Haitian heritage

10.  Plaintiff SATAEL ANTOINE is A Born Citizen of the United States, born November 1, 2008 and a resident of the State of New Jersey, and is also of African descent and Haitian heritage.

11.  Defendants JUDGES, EMPLOYEES, CORRECTIONAL OFFICERS, and JOHN and JANE DOES are and were at all times relevant herein duly appointed and acting officers, servants, employees and agents of THE TOWNSHIP OF BELLEVILLE and/or THE BELLEVILLE MUNICIPAL COURT, a municipal agency of defendant THE TOWNSHIP OF BELLEVILLE, THE ESSEX COUNTY CORRECTIONAL FACILITY. Defendants JOHN and JANE DOES are were at all times relevant herein acting under the directions and control of THE TOWNSHIP OF BELLEVILLE, THE ESSEX COUNTY CORRECTIONAL FACILITY and/or THE BELLEVILLE MUNICIPAL COURT, and same were improperly acting pursuant to either official, or the custom, practice and usage of the of THE TOWNSHIP OF BELLEVILLE, THE ESSEX COUNTY CORRECTIONAL FACILITY and/or THE BELLEVILLE MUNICIPAL COURT.

12.  Defendant MAYOR is and was at all times relevant herein the Mayor of the TOWNSHIP OF BELLEVILLE, its highest election official, its chief executive officers and the chief policy making official for the TOWNSHIP OF BELLEVILLE and its departments and offices. Defendant is THEREFORE sued in his official capacity.

13.  Defendant BELLEVILLE MUNICIPAL COURT is and was at all times relevant herein the Chief of Law Enforcement of the MUNICIPALITY OF BELLEVILLE, and was and is responsible for and the chief architect of, the policies, court procedures, issuance of fake or improper bench warrants, practices and customs of THE BELLEVILLE MUNICIPAL COURT, Defendant JUDGES and employees are sued in their official capacity. These facts EQUALLY applied to the Defendants and Employees of the ESSEX COUNTY CORRECTIONAL FACILITY.

14.  Defendant TOWNSHIP OF BELLEVILLE is and was at all times relevant herein a municipal entity created and authorized under the laws of New Jersey; it acts as agent to THE TOWNSHIP OF BELLEVILLE in the area of law enforcement, Defendants TOWNSHIP OF BELLEVILLE, THE BELLEVILLE MUNICIPAL COURT AND THE BELLEVILLE POLICE DEPARTMENT Assume the risks, undisputable mistakes, factual errors incidental to maintenance, accurate procedures, and proper operations of a Municipal Court and the employment of Court officers as said risk attaches to the public consumers of the service provided by members of THE BELLEVILLE MUNICIPAL COURT. Defendant TOWNSHIP OF BELLEVILLE and BELLEVILLE MUNICIPAL COURT were at all times relevant herein, the public employers of defendants mayor, Court employees, John Does, Jane Does, and judges.

15.  At all times relevant herein, defendants JUDGES, JAIL CUSTODIANS, CORRECTIONAL OFFICERS, JOHN AND JANE DOES were acting under color of the laws, statutes, ordinances, regulation, policies, procedures, improper enforcements, customs and usages of the State of New Jersey, THE TOWNSHIP OF BELLEVILLE and/or THE BELLEVILLE MUNICIPAL COURT, and were acting in the course and scope of their duties and functions as officers, agents, servants and employees of THE TOWNSHIP OF BELLEVILLE and/or THE MUNICIPAL COURT OF BELLEVILLE, and otherwise performed and engaged in conduit incidental to the performance of their lawful functions in the course of their duties. At all times relevant herein. They were acting for and on behalf of THE TOWNSHIP OF BELLEVILLE, THE ESSEX COUNTY CORRECTIONAL FACILITY, and/or THE BELLEVILLE MUNICIPAL COURT, with the power, enforcement and improper authority vested in them as officers, agent’s servant’s employees of THE TOWNSHIP OF BELLEVILLE, THE ESSEX COUNTY CORRECTIONAL FACILITY, and/or THE BELLEVILLE MUNICIPAL COURT.

“STATEMENT OF FACTS COMMON TO ALL CAUSE OF ACTION”

16.  On April 08, 2009 Dr. MAX DENIS ANTOINE, few of his employers’ good faith clients, along with several of other employees – were present at the American Corporate Society, located on the First floor at 114 Broughton Avenue, Township of Bloomfield, New Jersey.

17.  At approximately 1:30 p.m. Defendants’ arresting agents or third party police agents from Essex County and Bloomfield Police forcibly, and improperly Entered the Plaintiff’s office without legal justification, proper warrants except for an improper fabricated warrant for an illegal search of the plaintiff’s friend BMW which of course was dully parked on the Street next to the business on an unrelated matter; without process of service except for a fake expunged mistaken warrant maliciously and conspiratorially issued by Defendants Township of Belleville and the Belleville Municipal Court, without equal protection of the law, nor consent of the occupants. See Exhibit # A. (NOTICE OF CLAIMS AGAINST THE TOWNSHIP OF BELLEVILLE, BELLEVILLE MUNICIPAL COURT & ESSEX COUNTY CORRECTIONAL FACILITY).

18.  Defendants Essex County Correctional Facility maliciously and mistakenly processed, fingerprinted, photographed, and booked Plaintiff Dr. Max D. Antoine improperly, in reliance of the Said expunged warrant for a non criminal municipal ordinance which was completely dismissed in 2005 by Defendant Belleville Municipal Court and subsequently expunged by Plaintiff’s former attorneys Marc E. Sapin of Jersey City, and Daniel Kelley of Cherry Hill, New Jersey. Defendants have therefore unlawfully and mistakenly incarcerated the Plaintiff without probable cause and due process of State and Federal laws. Plaintiff remained incarcerated for approximately three long days. Dr. Antoine was subsequently released upon payment of a $200.00 Bail, paid by his family members to the Belleville Municipal Court. The Bail money was refunded back to the Plaintiff without apology, except acknowledgement of the undisputable fact that it was a mistake that the said warrant was still active and never recalled by the court. See Exhibits# B and # C (Copy of the Bail receipt and the $200.00 refundable check issued by the Defendants).

19.   On April 08, 2009, in the course of this conspiratorial imprisonment, Plaintiff Dr. Antoine (an already paraplegic crippling individual, wheelchair-bound) was negligently and recklessly lifted by three guards and put to sleep on an unsecured single bed, in a single unsecured isolated cell despite the Plaintiff’s repeated requests not to be put to sleep on that said bed. The bed seemed to be a remarkable hospital type bed without secured side rails. The bed was approximately 3 to 5 feet height. The isolated cell and the bed were not wheelchair accessible, or even accessible to the Plaintiff’s crippling health ailments. On the night of April 09, 2009, while unconsciously or unknowingly sleeping, Plaintiff slipped and fell off the said unsecured bed to the ground of that isolated cell in great neuro-skeletal pains. Plaintiff was carelessly left on the floor without help and assistance except for few pain killers upon insistence. On his last day, Plaintiff was then transferred to a much lower height bed in a different bulk cell with another inmate from out of State (Florida), he remained in that common cell for approximately less than three hours, then he was released to his family for medical follow ups.

20.  As a result, Plaintiff sustained aggravated physical and psychological injuries, irreparable pain and chronic sufferings at the hands of the said Defendants. The Said injuries will additionally require great amounts of monies for ongoing medical treatments, and future medical care from the Plaintiff.

21.  As a result, Plaintiff also sustained great financial losses including loss of income, personal income, ongoing legal fees for his criminal defense, numerous attorney fees, ongoing litigation costs, court costs, foreclosure on his properties, creditors collectable debts, legal fees and loss of financial maintenance for the ongoing support of his family.

DEPRIVATION OF RIGHTS UNDER THE UNITED STATESCONSTITUTION AND 42 U.S.C – 1964, 1970, 1981, 1983 AND 1985

22.  The Plaintiffs incorporate by reference the allegation set forth Paragraph 1 through 21 as if fully set forth herein.

23.  The conduct and actions of defendants, Acting under color of law, in entering the Plaintiff’s place of employment, without probable cause or legal justification, in falsely arresting and maliciously prosecuting DR. MAX D. ANTOINE, in falsely imprisoning DR. MAX D. ANTOINE, and in causing injuries to DR. MAX D. ANTOINE, was done intentionally, carelessly, negligently, maliciously, and/or with reckless disregard for the natural and probable consequences of their acts, was motivated. And/or with reckless disregard for the natural and probable consequences of thief acts, was motivated by race and/or nationality-based. Invidiously discriminatory animus, was done in retaliation for DR. MAX D. ANTONINE’S exercise of his First Amendment rights to free speech and his rights to free business employment, was done without lawful justification, and was designed to and did cause damage and injury in violation of DEFENDANTS’ rights as guaranteed under 42 U.S.C – 1964, 1981, 1983, 1985 and the United States Constitutions including its First, Fourth, Fifth, and Fourteenth Amendments.

24.  As a direct and proximate result of the defendant’s conduct complained of herein, Defendants sustained specific and serious bodily injury, pain and suffering, extreme terror, extreme humiliation, extreme intimidations, extreme retaliations, reprisal, extreme ongoing conspiracy, illegal search and seizure, invasion of the right to privacy of liberty, property, mental anguish, physical, emotional and psychological injury.

FALSE ARREST, DETENTION, AND IMPRISONMENT

25.  The plaintiffs incorporate by reference the allegation set forth in paragraph 1 through   24 as if fully set forth herein.

26.  By their failure to take any steps to protect DR. MAX ANTOINE, MAXINE ANTOINE, NELCHAEL ANTOINE, and SATAEL ANTOINE from the unjustified and unconstitutional treatment Dr. Max D. Antoine was receiving at the hands of the Defendants, in conspiring to falsify And fabricate an account surrounding the false arrest of DR. MAX ANTOINE, false imprison of DR.MAX ANTOINE, and negligent slip and fall of Dr. MAX ANTOINE, in falsifying and fabrication that account, and in conspiring to cover-up the injuries caused by the fall,  Defendants JOHN DOES and JANE DOES, acting under color of law and without lawful justification, intentionally, maliciously, with racially discriminatory animus, in retaliation for DR. MAX ANTOINE’S exercise of his First  amendment right to free speech, and safe employment and/or with deliberate indifference to or a reckless disregard for the natural and probable consequences of their acts, did cause damage and injury in violation of DR. MAX ANTOINE’S, vested rights as guaranteed under 42 U.S.C-1964, 1981, 1983, 1985 and the United States Constitution, including its First, Fourth, Fifth and Fourteenth Amendments, and the Federal ADA and LAD laws.

27.  As a direct and proximate result of the defendant’s conduct complained of herein DR. MAX D. ANTOINE, sustained specific and serious ongoing bodily injury, pain and suffering, extreme terror, extreme persecution, extreme humiliation, conspiratorial prosecutions, invasion of the right to privacy, property, licit employment, deprivation of liberty, mental anguish, physical, emotional and psychological injury.

THIRD CLAIM

MONELL CLAIM FOR CONSTITUTIONAL VIOLATIONS

28.  The plaintiffs incorporate by reference the allegations set forth in paragraph 1 through  27 as if fully set forth herein.

29.  At all times material to this complaint, defendants TOWNSHIP OF BELLEVILLE, BELLEVILLE MUNICIPAL COURT, ESSEX COUNTY CORRECTIONAL FACILITY acting through defendants JOHN DOES AND JANE DOES had in effect explicit written orders, as well as de facto policies, court procedures, trainings, practices and customs that were a direct and proximate cause of the unconstitutional conduct of the defendants detaining and arresting Officers.

30.  On classified information and accurate beliefs, Defendants THE TOWNSHIP OF BELLEVILLE, BELLEVILLE MUNICIPAL COURT, ESSEX COUNTY CORRECTIONAL FACILITIES failed to effectively train, LAWFULLY supervise and correctly discipline its officers, judges, and employees herein, so as to prevent violations of Citizen’s Constitutional Rights under State and Federal Law. Defendants of course failed to train, supervise and discipline its judges, officers and employees regarding unconstitutional conducts, thereby permitting and allowing the defendants judges, officers and employees to arrest, imprison, and severely injure Dr. MAX ANTOINE, and to otherwise cause them injury and violate their Federal and State Constitutional Rights, and/or to permit these actions to take place with the knowledge or consent of the judges, officers and employees of THE TOWNSHIP OF BELLEVILLE, BELLEVILLE MUNICIPAL COURT, AND ESSEX COUNTY CORRECTIONAL FACILITY.

31.  On public information and factual beliefs, the Defendants judges, officers and employees of THE TOWNSHIP OF BELLEVILLE, BELLEVILLE MUNICIPAL COURT, ESSEX COUNTY CORRECTIONAL FACILITY herein have been the subject of NUMEROUS prior Civilian, Judicial, and Departmental Complaints of Misconduct that gave notice to, or should have given notice to defendants THE TOWNSHIP OF BELLEVILLE, AND ESSEX COUNTY CORRECTIONAL FACILITY that the defendant police officers and employees herein were likely to engage in the conduct that would violate the Civil and Constitutional Rights of the Public, such as the conduct complained of by DR. MAX D. ANTOINE herein, and  OTHERS previously.

32.  As a result of the foregoing conscious policies, practices, procedures, customs, and/or usages Defendants THE TOWNSHIP OF BELLEVILLE, BELLEVILLE MUNICIPAL COURT, AND THE ESSEX COUNTY CORRECTIONAL FACILITY have permitted and allowed the employment and retention of individuals as judges, officers, agents, and employees whose individual circumstances, training and supervision place the public or segment thereof at substantial risks, negligence, recklessness of being the victims of unlawful and/or usages are a direct and proximate cause of the conduct alleged herein and otherwise a direct and proximate cause of the injuries of PLAINTIFF DR. MAX DENIS ANTOINE.

33.  As a direct and proximate result of the defendant’s conduct complained of herein, DR. MAX ANTOINE sustained specific and serious bodily injury, pain and suffering, extreme terror, extreme humiliation, extreme persecutions, malicious prosecutions, extreme defamation of his pure and excellent character, invasion of the Rights to privacy, deprivation of liberty and property, mental anguish, loss of self esteem, loss of employment, libel, slander, physical, emotional and psychological injury.

FOURTH CLAIM

RESPONDEAT SUPERIOR LIABILITY OF THE TOWNSHIP OF BELLEVILLE, BELLEVILLE MUNICIPAL COURT, AND   ESSEX COUNTY CORRECTIONAL FACILITY (JAIL)

34.  The plaintiffs incorporate by reference the allegation set forth in paragraph 1 through 33 as if fully set forth herein.

35.  The conduct of Defendants judges, officers, employees JOHN DOES and JANE DOES, alleged herein, occurred while they were on duty and in uniform, and/or and during the course and scope of their EMPLOYMENTS, duties and functions as judges, officers, paid employees. Therefore THE TOWNSHIP OF BELLVILLE, BELLEVILLE MUNICIPAL COURT, ESSEX COUNTY PROSECUTORS OFFICE are jointly and proximately liable to the Plaintiffs pursuant to the State common law doctrine of Respondeat Superior. (Let the Masters Answer)

FIFTH CLAIM

FALSE ARREST

36.  Plaintiffs NELCHAEL ANTOINE, MAXINE ANTOINE, SATAEL ANTOINE, as next friends, son, and daughters of Dr. MAX D. ANTOINE, incorporates by reference the allegations set forth in paragraph 1 thought 35 as if fully set forth herein.

37.  By the actions described above, Defendants jointly and falsely arrested DR. MAX D. ANTOINE, or caused Dr. MAX D. ANTOINE to be falsely arrested without reasonable or probable cause, illegally and with a fake fabricated expunged warrant, and without any rights or authority to do so. The Acts and Conduct of the Said above Defendants were the direct and proximate cause of injury and severe damage to Dr. MAX D. ANTOINE and further violated his Statutory and Common law rights guaranteed by law and Constitution of the State of New Jersey, and the United States of America to which it stands one Nation Under God the Indivisible.

38.  As a direct and proximate result of the Said Defendants’ egregious, negligent, reckless, and conspiratorial conducts complained of herein, Dr. MAX D. ANTOINE sustained numerous specific and severe serious bodily injury, pain and sufferings, extreme terror, extreme humiliation, conspiratorial persecutions, cover ups, malicious prosecutions, invasion of the rights to privacy, deprivation of liberty and property, mental anguish, physical, emotional and psychological injury.

SIXTH CLAIM

FALSE IMPRISIONMENT

39.  The plaintiffs incorporate by reference the allegations set forth in paragraphs 1 through 38 as if fully set forth herein.

40.  By the actions described above, Defendants falsely imprisoned DR. MAX ANTOINE, to be falsely imprisoned and maliciously detained without reasonable or probable cause, illegally with or without a fake expunged warrant, and without any rights or authority to do So. The egregious acts and cruel conducts of the Defendants were the direct and proximate cause of injury and severe damage to the Plaintiffs which further violated their Statutory and Common law rights as guaranteed by the laws and Constitution of the State of New Jersey, and the United States of America.

41.  As a direct and proximate result of the defendant’s conduct complained of herein, Dr. Max D. Antoine sustained numerous specific and serious bodily injury, pain and suffering, terror, extreme humiliation, conspiratorial persecutions, invasion of the rights to privacy, deprivation of liberty, mental anguish, physical, emotional and psychological injury.

SEVENTH CLAIM

SLIP AND FALL

42.  The plaintiffs incorporate by reference the allegations set forth in paragraph 1through   41 as if fully set forth herein.

43.  By the actions described above, defendants judges, officers, employees, JOHN DOES and JANE DOES did cause the slip and fall of DR. MAX D. ANTOINE at the isolated jail cell, The Egregious Acts and Conspiratorial Conducts of the Defendants were the direct and proximate cause of injury and severe damage to DR. MAX D. ANTOINE and violated his Statutory and Common law rights as guaranteed her by the laws and constitution of the State of New Jersey, and the United States of America.

44.  As a direct and proximate result of the defendant’s conduct complained of herein, Plaintiffs sustained numerous specific and severe serious bodily injury, pain and sufferings, extreme terrors, extreme humiliation, malicious prosecutions and persecutions, retaliation of his previous 1996 case, loss of income, invasion of the right to privacy, deprivation of liberty and property, death assassination threats, libel, slander, mental anguish, physical, emotional and psychologist injury.

EIGHTH CLAIM

INTENTIONAL AND NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

45.  The plaintiffs incorporate by reference the allegation set forth in paragraph 1 through 44 as if fully set forth herein.

46.  By the actions described above, Defendants engaged in extreme and outrageous conduct, egregious conduct utterly intolerable in a Civilized Cause of Injury and Damage to DR. MAX D. ANTOINE and violated his vested Statutory and Common law rights as guaranteed by the laws and Constitution of the State of New Jersey and the United States of America.

47.  As a direct and proximate result of the defendant’s malicious conduct complained of herein, DR. MAX D. ANTOINE, sustained specific and serious bodily injury, pain and suffering, terror, extreme humiliation, invasion of the right to privacy, deprivation of liberty, mental anguish, emotional and psychological injury

NINTH CLAIM

CONSPIRACY UNDER STATE LAW

48.  The plaintiffs incorporated by reference the allegation set in paragraphs 1 through 47 as if fully set forth herein.

49.  By the actions described above, defendants JOHN DOES AND JANE DOES jointly, individually, and severally, maliciously acting in their individual capacities and under color of law. Conspired together and maliciously and willfully entered into a scheme to deprive DR. MAX D. ANTOINE, of vested rights, property, liberty, and well-being and to commit the above-alleged unlawful acts. The acts and egregious conduct of the defendants were the direct and proximate cause of injury to DR. MAX D. ANTOINE, and violated protected rights as guaranteed by U.S.C – 1964, 1970, 1981, 1983, 1985 and by the United States Constitution, including its First, Fourth, Fifth, and Fourteenth Amendments, and violated his Statutory and Common law rights as guaranteed by the laws and Constitution of the State of New Jersey and the United States of America to which it stands one Nation under God the Indivisible.

50.  As a direct and proximate result of the defendants egregious conduct complained of herein, Plaintiffs sustained numerous specific and serious bodily injury, pain and sufferings, extreme terrors, extreme threats of assassination, extreme defamation, extreme alienation, humiliation invasion of the right to privacy, deprivation of liberty and property, extreme mental anguish, physical, emotional and psychological injury.

TENTH CLAIM

LOSS OF CONSORTIUM

51.  Plaintiffs NELCHAEL ANTOINE, MAXINE ANTOINE, SATAEL ANTOINE individually and in THEIR capacity as natural CHILDREN of DR. MAX D. ANTOINE incorporates by reference the allegation set forth in paragraph 1 through 50 as if full set forth herein.

52.  At all times mentioned herein, these children were and still are the lawful angelic children of DR. MAX D. ANTOINE; they did and still continue to live together Son, Daughters and vested Father.

53.  At all times mentioned herein, these angelic children were and still are the children of DR. MAX D.ANTOINE; they did and still continue to live together as a family.

54.  By the actions described above, Defendants recklessly engaged in intentional and negligent conduct which caused DR. MAX D. ANTOINE to sustain numerous specific and serious bodily injury, harms, financial ruins, and severe physical, emotional and psychological injury. As a direct and proximate result of Defendants egregious action complained of herein, NELCHAEL ANTOINE, MAXINE ANTOINE, SATAEL ANTOINE have been deprived of the services, companionship, guidance and support of their unique beloved father, DR. MAX D. ANTOINE, all in violation of their right as guaranteed by 42 U.S.C –1964, 1970, 1981, 1983, 1985 and by the United States Constitution, including its First, Fourth, Fifth and Fourteenth Amendments, and in violation of all their Statutory and Common law rights guaranteed by the law and Constitution of the State of New Jersey, and the United States of America to which it stands one Nation under God the indivisible.

ELEVENTH CLAIM

NEGLIGENCE

55.  The plaintiffs incorporate by reference the allegation set forth in paragraph 1 through 54 as if fully set forth herein

56.  By the actions described above, defendants JOHN DOES AND JANE DOES, jointly, individually, and severally, negligently cause injuries, harms, financial ruins, and emotional distress. The acts and egregious conduct of the defendants were the direct and proximate cause of injury and damage to DR. MAX D. ANTOINE and violated HIS vested Statutory and Common law rights as guaranteed by the laws Constitution of the State New Jersey, and the United States of America to which it stands one Nation under God the indivisible.

57.  As a direct and proximate result of the Defendants egregious conduct complained of herein, Plaintiffs sustained numerous specific and serious bodily injury, pain and sufferings, financial ruins, extreme terror, extreme retaliation, reprisal, extreme humiliation invasion of the rights to privacy and property, extreme ongoing persecutions, conspiratorial persecution, deprivation of liberty, mental anguish, physical, emotional and psychological injury.

TWELVETH CLAIM

LACK OF SAFETY & ACCESSIBILITY

58.  Plaintiff DR. MAX D. ANTOINE repeats and re-alleges each and every claim contained within Paragraph 1 through 57 against all the Defendants, as though set forth in full herein.

59.  Defendants ESSEX COUNTY CORRECTIONAL FACILITY, JOHN DOES, JANES DOES, have breached the Plaintiff’s Safety and Full Accessibility rights under the Federal ADA Act, by failing to provide him with proper Cell Accommodations, and by exposing the Plaintiff to egregious health hazards; including an unsafe bed, unsafe toilet, unsanitary jail environment. These hazards constitute serious health consequences and potential danger against the Plaintiff well being as a Crippled Paraplegic, and other potential future Disabled Inmates. The Defendants have therefore egregiously and recklessly violated the Federal American with Disability Act in its entirety.

60.  As a result of the Said violations, Plaintiff DR. MAX D. ANTOINE, was carelessly and negligently forced upon an unsafe bed against his will as a Paraplegic Prisoner (FALSE INCACERATION) by the Defendants, knowing that the Said bed had no factual Side Rail, and may even cause him severe Physical Traumatic Injury.

61.  As a result of the Said fall, Plaintiff Dr Max D Antoine did in fact fall off the Said bed and physically injured himself with aggravated injuries, which were not in fact treated by the Defendants notwithstanding his numerous repeated requests and remarkable Crippling Pain and Sufferings.

62.  As a direct and proximate result of the Defendants reckless and malicious conduct complained of herein, Plaintiff sustained numerous specific and serious bodily harms, injury, pain and sufferings, medical treatments, financial ruins, extreme terror, extreme persecution, conspiratorial prosecution, extreme retaliation, extreme threats of death, deprivation of property, liberty, mental anguish, physical, emotional, and psychological injury at the hands of these Defendants.

THIRTEENTH CLAIM

CONSPIRATORIAL DEFAMATION

63.  Plaintiffs repeat and re-allege each and every of their claims contained within Paragraphs 1 through 62, as though set forth in full herein.

64.  The fake fabricated or expunged negative warrant of the Defendants was false, disparaging, defamatory, derogatory, degrading, conspiratorial, retaliatory, misrepresented to the public, and misleading.

65.  Defendants’ false fabricated warrant or mandate for arrest made publicly knowing of its falsity, or in reckless disregard for its factual truth and standing.

66.  Such false fabricated warrant have proximately caused and continue to cause irreparable injury to Plaintiffs’ employment the American Corporate Society, and personally to DR. MAX DENIS ANTOINE’S public image and excellent reputations.

67.  As a direct and proximate result of Defendants’ false expunged warrant and defamatory statements plaintiffs have been damaged in an amount to be proven at jury trial.

68.  Furthermore, Defendants defamatory statements and false fabricated warrant are constitutionally and statutorily actionable per se.

69.  Defendants defamatory statements and false fabricated warrant were recklessly, egregiously committed with public wanton and malicious disregard for the factual truth, such that extreme punitive damages are licitly warranted.

FOURTEENTH CLAIM

FALSE LIGHT

70.  Plaintiffs repeat and re-allege each and every of their claims contained within paragraph 1 through 71 against all the defendants, as though set forth in full herein.

71.  Defendants false fabricated warrant and defamatory statements have constitutionally and statutorily placed Plaintiff DR. MAX DENIS ANTOINE in a false light.

72.  The false light in which all the Plaintiffs have been placed as a proximate result of Defendants false statements, fabricated expunged warrant and actions would be highly and egregiously offensive to a reasonable person.

73.  Defendants factually knew the statements and impressions created by their conspiratorial actions were remarkably false, or Defendants acted in reckless egregious disregard for the truth or extreme falsity of those statements and costly impressions.

74.  Defendants wrongful acts were maliciously committed with egregious wanton and malicious disregard for the truth, such that extreme punitive damages are licitly warranted.

75.  As a direct and proximate result of Defendants wrongful statements, fabricated warrant, and conspiratorial actions, Plaintiffs have been severely damaged in an extreme amount to be proven at jury trial.

FIFTHTEENTH CLAIM

DECLARATORY JUDGEMENT

76.  Plaintiffs repeat and re-allege each and every of their vested claims contained within Paragraphs 1through 75, as though set forth in full herein.

77.  Apparently, a lawful controversy has arisen between all the Plaintiffs and all the Defendants with respect to their respective rights.

78.  Based upon the facts claimed above, Plaintiffs request that this District court congressionally and constitutionally exercise its full vested powers under the Declaratory Judgments Act, 28 U.S.C. 2201-02 to lawfully DECLARE that the False Expunged Warrant and the Defamatory Statements made, publicly published, and created by Defendants were and are presently false.

79.  It is imperatively mandatory and licitly appropriate, in order to prevent further irreparable damage, potential harms, and extreme injury to all the Plaintiffs that this District court enter such immediate lawful DECLARATION with prejudice.

80.  Plaintiffs Constitutionally, Statutorily have no adequate remedy at Law.

81.  To the extreme extent applicable and where authorized by law, Plaintiffs are lawfully entitled to attorneys’ fees, costs, expenses incurred in SECURING DECLARATORY RELIEF and REDRESS.

SIXTEENTH CLAIM

INJUNCTIONS AS TO DEFENDANTS JOHN AND JANE DOES

82.  Plaintiffs repeat and re-allege each and every of their claims contained within Paragraphs 1 through 81, as though set forth in full herein.

83.  Based upon the Proven Facts alleged above and Exhibits Attached herewith, Plaintiffs request that this District court enjoin Defendants from making, publishing, posting, fabricating, defaming, conspiring, harming, defacing, or continuing to make, false, disparaging, defamatory, derogatory, malicious and misleading statements regarding the said fabricated warrant, or otherwise defaming and assassinating Plaintiffs.

84.  Such immediate relief is imperatively necessary and appropriate in order to prevent public irreparable harms and further injury to Plaintiffs.

85.  Plaintiffs have therefore no adequate remedy at Law.

WHEREFORE; Plaintiffs DR. MAX D. ANTOINE, NELCHAEL ANTOINE, MAXINE ANTOINE, and SATAEL ANTOINE demand judgment against Defendants JOHN DOES, JANES DOES, BELLEVILLE MUNICIPAL COURT, BELLEVILLE TOWNSHIP, AND ESSEX COUNTY CORRECTIONAL FACILITY for the following Statutorily relief:

a)             A Jury Award of actual, compensatory, economic, consequential, and punitive damages against all the Defendants;

b)            Declaratory Relief as imperatively requested under Federal Law;

c)             Injunctive Relief enjoining all the Defendants from fabricating, making, inventing, further creating, threatening, harming, injuring, defaming or continuing to make false, conspiratorial, malicious, derogatory, retaliatory, misleading, or otherwise defaming and framing the Plaintiffs;

d)            For all costs, financial restitutions, expenses, fees, incurred herein; and

e)             Such Other Relief as this District court deems to be just and equitable.

COMPLAINT VERIFICATION

I, Dr. Max Denis Antoine, Declare under oath and under penalty of perjury, under the Laws of the State of New Jersey, that I am the main Plaintiff herein, that the information contained in this foregoing Complaint is accurately true and absolutely correct to the best of my Direct and Proximate Knowledge and Factual Belief, and I am authorized to further make this Verification on behalf of the other Plaintiffs including Nelchael Antoine, Maxine Antoine, and Satael Antoine.

Signed on this 25^th Day of February, 2010

BY:       ______________________________________

DR. MAX DENIS ANTOINE,

VICTIM & PRO SE LITIGANT