RECEIVED JAN 2.2 2015 THE LAW OFFICES OF ae ee! BENEDETTS® 1613 South Broad Street Philadelphia, PA 19148 Phone (215) 389-1900 Facsimile (215) 271-8910 Borough af Rosalie Park ‘Borough Clerk's Office CONRAD J. BENEDETTO * NEW SEH cr, THOMASG, MASCIOCCHIY 1814 East Route 70-Suite 350, are (Cherry Hil, New Jersey 08003 JACOB L, CROCKETT “Telephone: (856) 983-7033 WILLIAM TROZELL** Facsimile: (215)271-8910, + MEN@EROFPA& NIBAR PLEASE REPLY 1! ** MEMBER OF PA & NC BAR Philadelphia - Broad Street Office January 20, 2015 VIA CERTIFIED MAIL R/RIR # 7013 3020 0002 1366 3571 & REGULAR MAIL/ HAND DELIVERY Doreen Cali, Municipal Clerk Borough of Roselle Park 110 East Westfield Avenue Roselle Park, NJ 07204 ATTN: Administrator of Tort Claims RE: NOTICE OF TORT CLAIM Client: Michael Yakubov Date of Incident: 10-25-2014 Dear Sir/Madame, Please be advised that this office has been retained to represent Michael Yakubov for injuries/damages sustained as a result of the actions of the Roselle Park Police Department Pursuant to N.J.S.A. 59:8-4, please be advised as follows: 1. Claimant Information: ] Date of | Social Security Claimant Name _| Address Birth Number 146 West Lincoln Avenue, Roselle Park, NI | Michael Yakubov_| 07204 | Ifnotices and correspondence in connection with this claim are to be sent to a person other than it, complete item #2. &Conrad J. Benedetto, Esquire Law Offices of Conrad J, Benedetto 1615 S. Broad Street Philadelphia, PA 19148 Relationship to Claimant: (X)_ Attomey at Law () Other: Explain Relationship ‘The occurrence or accident which gave rise to this claim: a. Date: 10/25/2014 Time: At or about b. Describe the location or place of the accident or oceurrence: Municipality: Borough of Roselle Park, NJ Exact Location of the Occurrence: West Lincoln Avenue and Larch Street . Describe how the accident or occurrence happened: Ifa diagram will assist your explanation, please use the reverse side of this form: Michael Yakubov was detained by RPPD, arrested and charged with two counts (1) Criminal Mischief and (2) Disorderly Persons Offense. The police created a sting operation in or near Michael Yakubov's home. 4. State the name and address of the State agency or agencies that you claim caused you damage: [Agene Address | Roselle Park Police Department 110 East Westfield Avenue, Roselle Park, NJ 07204 Borough of Roselle Park 110 East Westfield Avenue. Roselle Park, NJ 07204 State the names of State employees whom you claim were at fault, including any information that will assist in identifying and locating them: Sgt. Matthew Disano Richard Gaylord Doreen Cali, Clerk Former Mayor Joseph Accardi Detective Theodore Dima Mayor Carl Hokanson Police Chief Paul Morrison Patrolman William Hannon Richard Huxford, Borough Attorney 2€. State the negligence or wrongful acts of the State agency and State employees which caused your damages: Motivated sting operation that led to the detention and false arrest of Mr. Michael Yakubov Exhaustive attempts to implicate Mr. Yakubov in voter intimidation tactics and attempts to implicate Mr. Yakubov as the chief cause for police services at polling locations in 2014 general election. Over persecution of Mr. Michael Yakubov by the Roselle Park Police Department. Purposeful false estimate of damaged “sign” cost in order to access charges. Targeting of Mr. Yakubov by the Roselle Park Police Department during 2014 election cycle. Extraordinary and out of the ordinary use of police powers for investigation of sign theft Targeting of Michael Yakubov and threatening of Mr. Michael Yakubov by Mayor Accardi at Council ‘meetings and at the Cruisin Night Car Show in 2011 as recorded by the Union County Prosecutor. Mayor Accardi’s statements after incident involving the arrest of Michael Yakubov. Beginning of Construction work in front Mr. Yakubov's home, limiting access to home. Release of interrogation video to media sources. Release of arrest and other records to media sources. Use of police influence by Mayoral Candidate (Mayor) Carl Hokanson and use of overall police influence to target Mr. Yakubov. Damages: Resulting in loss of 2014 Mayoral Election, name slander/ name libel, release of police evidence and police interrogation video, stress, threat of employement loss, emotional distress, public humiliation, violation of personal rights, false arrest, false imprisonment, malicious prosecution, deviation of time from work and family. Out of pocket cost for legal services and municipal court fines. 12 Month Conditional Dismissal Program stress, fuel costs to fom court/probation/legal. Emotional and psychological distress of pregnant wife Rory Yakubov, 2.5 year old Son Nathan. Deliberate action attributable to the municipality directly caused a deprivation of federal rights. Damages related to future employment (Nationwide). Causality and stress leading to councilman moving and resigning. f£ State the name and address of all witnesses to the accident or occurrence: Investigation still continuing, Claimant Name | Address TBS See Police Report Richard Templeton 148 West Lincoln Avenue, Roselle Park Adrian Kemp 144 West Lincoln Avenue, Roselle Park Rory Yakubov __| 146 West Lincoln Avenue, Roselle Park | Richard Gaylord _| Roselle Park Police Department Michael Yakubov | 146 West Lincoln Avenue, Roselle Park } Joseph Delorio | 824 Larch Street, Roselle Park | Other names may be provided, pending further investigation and discovery process.2. State the name of all police officers and police departments who investigated the accident Agency Roselle Park Police Department Officer Richard Gaylord 110 East Westfield Avenue, Roselle Park, NJ 07204 | | Sgt. Matthew Disano Lt. Theodore Dima 110 East Westfield Avenue, Roselle Park, NJ 07204 110 East Westfield Avenue, Roselle Park, NJ 07204 | Agene Detective Cassie Kim County of Union Prosecutor's Office 32 Rahway Avenue, Elizabeth, NJ 07202 (Other names may be provided, pending further investigation and discovery. 4a, Claim for Damages (check appropriate block), (XX) Personal Injury (Property Damage (X) Other Ifother, explain in detail: CIVIL RIGHTS VIOLATIONS 4b. Ifyou claim personal injury: (1) Describe your injuries resulting from this accident or occurrence: Stress, financial loss, mental, emotional damage, reputational damage, violation of civil rights. 2) Do you claim permanent disability resulting from the injury: Yes If yes, describe the injuries believed to be permanent. Reputational Damage, Emotional and Mental Stress, Anxiety, Agoraphobia, (3) For each hospital, doctor, or other practitioner rendering treatment, examination or diagnostic serviee, state: [ Name of Hospital Address Dates of Treatment | Amount of Charges | Amount Paid or Doctor or Other Or Services ToDate Payable by Other Facility Sources Such as Insurance Pendin (4) Ifyou claim toss of wages or income as a result of the injury, state: Name of Employer: Borough of Roselle Park (Mayoral Salary) ~subsequent Council Salary. William Paterson University — Wayne, NINote: Address of Employer: 110 East Westfield Avenue, Roselle Park NJ 07204 1600 Valley Road, Wayne NJ Your Occupation: Councilman Ward 5 / Academie Director -WPU Date Employed at This Job: Jan 2, 2006 — Present and July 1, 2014- Present Rate ofPay: Council Payand/ and /year Dates of Absence from Work: WPU: Nov 4%, 2014, Nov 25, 2014, Jan 20" (1/2 day) 2014. Total Lost Wages to Date: Est. $505.20 Lost vacation time/ If Still Out of Work, Expected Date of Return: If your claimed loss of income arises from self-employment or other than wages, attach a Calculation showing the basis of your calculation of lost income. Legal Cost (1,000) may include additional legal costs, $200.00 court/municipal fees. $2.00 parking fee probation office. Set forth any and all other losses or damages claimed by you: No other losses or damages at this time, Additional damages to be supplied if discovered after additional discovery and investigation. If you claim property damage: a) @) @) @ (5) (6) M (8) (9) Describe the property damaged: Residence where the incident took place. The present location and time when the property may be inspected: Inspection available upon request. Date property acquired: Cost of the property: s Value of property at time of accident: s Description of damage: Has the damage been reported? If'so, by whom when and cost of repairs Attach each estimate of repair costs to this form. Set forth in detail the loss claimed by you for property damage:Set forth in detail all other items of loss or damages claimed by you and the method by which you made the calculation, ‘To be supplied. ‘The amount of the claim: Unknown at present, investigation continues Have you made a claim against anyone else for any of the losses or expenses claimed in this notice? Not at this time. Ifyes, set forth the names and addresses of all persons and insurance companies against whom you have made such claims: Are any of the losses or expenses claimed herein covered by any policy of insurance? Not at this time, Claimant reserves the right to Amend. Have you received or agreed to receive any money from anyone for the damages claimed herein? If so, Set forth the details of such agreement. No. The following items must be submitted with this notice: (1) Copies of itemized bills for each medical expense and other losses and expenses claimed. Will Provide when becomes available. (2) Full copies of all appraisals and estimates of property damage claimed by you. (3) Copies of all written reports of all expert witnesses and treating physicians ‘None at present will provide when available. I hereby certify that the foregoing statements made by me are true based upon information and belief, that the attached statements, bills, reports and documents are the only ones known to me to be in existence at this time. I am aware that if any statement made herein is willfully false or fraudulent, that I am subject to punishment provided by law. Dated: January 20, 2015 Conrad J. Benedetto, Esquire LAW OFFICES OF CONRAD J. BENEDETTO Attomey for Claimant 6